Section 835I defines "chargeable income" as meaning 'the undistributed income of a controlled foreign company which is subject to a controlled foreign company charge'. Undistributed income means the distributable profits for the accounting period of a CFC less any relevant distribution. The full definition is set out in section 835Q.  Under section 835R, the amount of undistributed income that the CFC charge can arise on is the portion included in the accounting profits of the company available for distribution that is attributable to the relevant Irish activities i.e. Irish SPFs, where those SPFs were instrumental in generating the income and the arrangements involving the SPFs were non-genuine (i.e. the CFC would not have owned the assets nor borne the risks that it did were it not for the Irish SPFs). A CFC charge will therefore arise if those arrangements were non-genuine and were put in place for the essential purpose of avoiding tax..