Выражение встречается в следующем контексте:
Previously, there was a provision contained in the UK tax law that where a DTT (double tax treaty) tiebreaker clause attributed residence to the non-UK territory, then for all UK tax purposes the company should be treated as non-resident in the UK. Following a change in the law, which came into force on April 1, 2002, this specific provision does not apply for CFC purposes. Therefore a subsidiary of a non-UK resident but UK incorporated company will still be subject to the UK CFC regime

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