Foreign business establishment (FBE): 
the net income of a CFC is deemed to be nil if all receipts and accruals are attributable to an FBE, defined as:    
(a) a fixed place of business located in a country other than the Republic that is used or will continue to be used for the carrying on of the business of that CFC for a period of not less than one year, where—
(i) that business is conducted through one or more offices, shops, factories, warehouses or other structures;
(ii) that fixed place of business is suitably staffed with on­site managerial and operational employees of that controlled foreign company who conduct the primary operations of that business;
(iii) that fixed place of business is suitably equipped for conducting the primary operations of that business;
(iv) that fixed place of business has suitable facilities for conducting the primary operations of that business; and
(v) that fixed place of business is located outside the Republic solely or mainly for a purpose other than the postponement or reduction of any tax imposed by any sphere of government in the Republic  
(b) place where prospecting / exploring / producing natrual resources
(c) a construction site lasting for at least 6 months   
(d) agricultural land used for bone fide farming activities 
(e) ships, vehicles, rolling stock and aircraft operated by the CFC or group company in a particular country.