The exemptions that apply include scenarios where the CFC pays a comparatively higher amount of tax in its territory than it would have paid in the State (section 835T Effective tax rate exemption), the low profit margin exemption (section 835U), the low accounting profit exemption (section 835V) and the exempt period exemption (section 835W).  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 the Transfer Pricing regime under Part 35A, TCA (section 835R). 