A controlled foreign taxable subject (i.e. CFC) means: 1) a controlled foreign taxable entity; 2) a permanent establishment of a Lithuanian entity whose income is not attributable to the tax base of the Lithuanian entity.  A controlled foreign taxable entity means a foreign entity where a Lithuanian entity alone or together with associated persons on the last date of the tax period of this foreign entity directly or indirectly owns more than 50 % of shares (interests, member shares), voting rights or rights to the share of distributable profits or exclusive rights to purchase them.  The income of the CFC is taxed only if: 1) a CFC is registered or otherwise organised in the target territory (blacklisted jurisdiction); or 2) passive income of the CFC exceeds 1/3 of total income of this CFC during the tax period; and 3) actual corporate income tax paid on income of the CFC following the rules on corporate income tax or equivalent tax applied in this foreign state is lower than 50 % of actual corporate income tax on income of CFC which would have been computed following the Lithuanian CFC rules. For the purpose of this paragraph, CFC income includes only passive income.