The CFC rules will not apply where the arrangements under which SPFs are performed have been entered into on an arm's length basis or are subject to Ireland's Transfer Pricing regime. There are exemptions for CFCs with low accounting profits or a low profit margin. An 'effective tax rate' exemption can apply where the tax paid by the CFC in its jurisdiction is greater than the difference between the tax it pays in its territory and the tax it would have paid in the State. A one-year grace period is also allowed in respect of newly-acquired CFCs where certain conditions apply. Relief is also available on certain distributions and on certain disposals of shares or securities in a CFC. In order to prevent double taxation, a credit will be available for any tax paid by the CFC arising in its jurisdiction or any other jurisdiction (including Ireland) on the chargeable income.