What does the calculator actually do?

It runs a 2026-current factor-by-factor screen against the seven major CFC regimes (UK, Germany, France, Netherlands, Italy, Spain, US). For each regime it checks the ownership threshold, the regime-specific low-tax test, the passive-income test where required, the substance carve-out, the EU carve-out (France only), and computes net tax leakage after the foreign tax credit. It does not replace tax counsel — it surfaces whether your structure deserves a closer look.

Is this just a generic CFC tool with one rule for everyone?

No. Each regime has different mechanics: UK uses 75% of UK rate as the low-tax threshold; Germany uses an absolute 15% threshold (reduced from 25% in 2024); France uses 50% of French rate; Netherlands uses ≤ 9% statutory plus an EU non-cooperative list; Italy uses 50% of Italian; Spain uses 75% of Spanish; US NCTI applies broadly with no low-tax gating. UK individuals are not even covered by Part 9A — they are caught by the separate Transfer of Assets Abroad regime instead. The calculator handles each of these correctly.

How is the foreign tax credit modelled?

Net leakage = home-rate × inclusion − foreign-tax-paid (proportional to ownership). For US NCTI, we apply the 90% FTC haircut introduced post-OBBBA 2025. For all other regimes we apply 100% FTC up to the home tax cap. Real cases also depend on cross-crediting rules within tax basket categories — we do not model that.

Why does Pillar 2 matter here?

For groups over €750M consolidated revenue, the OECD Pillar 2 GloBE 15% minimum tax overrides most CFC carve-outs. If you are above that threshold, the calculator's "safe" verdict is misleading — Pillar 2 will catch what CFC misses. The calculator is calibrated for sub-€750M operators where Pillar 2 does not yet apply.

What does "genuine economic substance" actually mean?

Local employees making decisions, not just nominee directors signing pre-prepared paperwork. Documented board meetings held in the entity jurisdiction. Real office space, not a registered-agent address. Arm's-length intra-group pricing with proper transfer-pricing documentation. The exact bar varies by regime but the principle is consistent: if the tax authority can show the entity is run from the home jurisdiction, the carve-out fails.

Should I act on this output?

No. This is a screening tool — it tells you whether your structure deserves a closer look, not whether it is safe. Real CFC analysis requires a tax specialist who can review the specific corporate structure, the underlying contracts, the substance evidence, and the interaction with double-tax treaties. Treat the verdict as a starting hypothesis, never as a verdict.

CFC Exposure Calculator — 7 Regimes 2026

This is a screening tool, not legal advice.

Real CFC analysis is fact-specific and depends on contract review, transfer-pricing, substance evidence, treaty interactions, and the precise statutory text in each jurisdiction. Always engage qualified tax counsel in the home and entity jurisdictions before acting on any output here.

Inputs

UBO type

UBO tax residencyEntity jurisdictionActivity typeAnnual entity profit (EUR)UBO ownership %

Genuine economic substance?

Foreign tax already paid (€) — for FTC

Auto-defaulted from entity jurisdiction; override if you have actuals · 12.5%

Review required

UK CFC rules (TIOPA 2010 Part 9A) charge UK companies, not individuals. Individual UK UBOs are caught by Transfer of Assets Abroad (TOAA) provisions instead — separate regime, similar effect, requires separate analysis.

Factor-by-factor

Ownership ≥ thresholdYes

Foreign rate < low-tax thresholdYes

Substance carve-outNo

EU carve-outNo

Individual UBO covered by this regimeNo

Recommendations

1.Engage a UK private-client tax adviser to review TOAA exposure on the specific structure.
2.Consider whether the "motive defence" or "genuine commercial transaction" defence applies.
3.Substance and arm's-length pricing of intra-group flows are critical to the TOAA analysis.

Discuss these results with us.

We will look at your specific case, validate the numbers against our active banking partners, and give you a free, honest pre-approval read — usually within 24 hours.

⚠ For informational purposes only. This is not legal, tax, or financial advice. Verify with a qualified advisor before acting on any output.

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Methodology & sources

The calculator runs a six-factor test per CFC regime: ownership threshold, regime-specific low-tax test, passive-income test (where required), substance carve-out, EU carve-out (France only), and individual-vs-corporate UBO coverage. If all triggering factors fire and no carve-out applies, the regime catches.

Per-regime detail (2026-current):

UK — TIOPA 2010 Part 9A. ≥25% interest. Tax exemption if foreign tax ≥ 75% of UK tax (effective rate ≥ 18.75% with UK CT at 25%). Charged at the apportioned company's CT rate. Individual UBOs are not caught by CFC — they fall under the separate Transfer of Assets Abroad (TOAA) regime.
Germany — AStG §§ 7-14 (Hinzurechnungsbesteuerung). >50% control by German residents. Low-tax = effective foreign tax < 15% absolute (reduced from 25% in 2024 by the Minimum Tax Directive). Active-business carve-out under § 8 Abs. 2.
France — Article 209 B CGI. >50% control (drops to 5% if the entity is listed). Low-tax = foreign effective tax < 50% of French (i.e. < 12.5% with French CT at 25%). EU companies excluded unless the structure is artificial.
Netherlands — ATAD Model A (since 2019). Low-tax = statutory rate ≤ 9% OR on the Dutch list of low-tax / EU non-cooperative jurisdictions. Tainted passive income is included; substance carve-out for genuine economic activity.
Italy — Article 167 TUIR. >50% control. Low-tax = foreign effective tax < 50% of Italian (< ~12% with IRES at 24%). Passive income must exceed 50% of total. Optional 15% substitute tax election available since Decree 209/2023.
Spain — Article 100 LIS (Transparencia Fiscal Internacional). ≥50% control. Low-tax = foreign tax < 75% of Spanish (< ~18.75%). Substance carve-out under Art 100.2.
US — Subpart F + NCTI (formerly GILTI, renamed under OBBBA 2025, effective 2026). ≥10% US shareholder. Effective US rate on NCTI is 12.6% (Section 250 deduction reduced to 40%). 90% FTC available. QBAI 10% return exclusion eliminated for 2026.

Tax math. Net leakage = (home rate × inclusion amount) − foreign tax credit. The FTC is the foreign tax already paid in the entity jurisdiction, proportional to UBO ownership, capped at the gross home tax. For US NCTI we apply the 90% FTC haircut.

What this tool does not model. Specific double-tax treaty interactions; cross-crediting between FTC basket categories; transfer-pricing adjustments; arrangements involving permanent establishments; the look-through rules for tiered structures; Pillar 2 GloBE for groups over €750M consolidated revenue (which overrides most CFC carve-outs).

This is a screening tool. Real analysis requires a tax specialist who can review the specific corporate structure, contracts, substance evidence, and treaty interactions. Treat any output as a starting hypothesis, never a verdict.

Sources

Frequently asked questions

What does the calculator actually do?: It runs a 2026-current factor-by-factor screen against the seven major CFC regimes (UK, Germany, France, Netherlands, Italy, Spain, US). For each regime it checks the ownership threshold, the regime-specific low-tax test, the passive-income test where required, the substance carve-out, the EU carve-out (France only), and computes net tax leakage after the foreign tax credit. It does not replace tax counsel — it surfaces whether your structure deserves a closer look.
Is this just a generic CFC tool with one rule for everyone?: No. Each regime has different mechanics: UK uses 75% of UK rate as the low-tax threshold; Germany uses an absolute 15% threshold (reduced from 25% in 2024); France uses 50% of French rate; Netherlands uses ≤ 9% statutory plus an EU non-cooperative list; Italy uses 50% of Italian; Spain uses 75% of Spanish; US NCTI applies broadly with no low-tax gating. UK individuals are not even covered by Part 9A — they are caught by the separate Transfer of Assets Abroad regime instead. The calculator handles each of these correctly.
How is the foreign tax credit modelled?: Net leakage = home-rate × inclusion − foreign-tax-paid (proportional to ownership). For US NCTI, we apply the 90% FTC haircut introduced post-OBBBA 2025. For all other regimes we apply 100% FTC up to the home tax cap. Real cases also depend on cross-crediting rules within tax basket categories — we do not model that.
Why does Pillar 2 matter here?: For groups over €750M consolidated revenue, the OECD Pillar 2 GloBE 15% minimum tax overrides most CFC carve-outs. If you are above that threshold, the calculator's "safe" verdict is misleading — Pillar 2 will catch what CFC misses. The calculator is calibrated for sub-€750M operators where Pillar 2 does not yet apply.
What does "genuine economic substance" actually mean?: Local employees making decisions, not just nominee directors signing pre-prepared paperwork. Documented board meetings held in the entity jurisdiction. Real office space, not a registered-agent address. Arm's-length intra-group pricing with proper transfer-pricing documentation. The exact bar varies by regime but the principle is consistent: if the tax authority can show the entity is run from the home jurisdiction, the carve-out fails.
Should I act on this output?: No. This is a screening tool — it tells you whether your structure deserves a closer look, not whether it is safe. Real CFC analysis requires a tax specialist who can review the specific corporate structure, the underlying contracts, the substance evidence, and the interaction with double-tax treaties. Treat the verdict as a starting hypothesis, never as a verdict.

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Disclaimer

This calculator is for informational purposes only. It does not constitute legal, tax, or financial advice. Licence fees, tax rates, and regulatory requirements change. You must consult a qualified advisor in each relevant jurisdiction before making any commercial or investment decision. GetBanked and BMC Strategic Inc accept no liability for decisions made on the basis of these calculations.

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