Yes, if the CFC actively engages in business operations through an office, a shop, or a factory, in the foreign jurisdiction then the CFC rules will not apply. This exemption, however, does not apply to a CFC: (i) which is engaged in certain businesses such as wholesale trade, financial and insurance business, real estate, lease business, etc. or (ii) which derives passive incomes from holding stocks or bonds, provision of intellectual property rights, leasing of vessels, aircraft, and heavy equipment, etc.