The SPF approach in relation to trading profits and non-trade finance profits effectively applies a test of substance or relevant activity at an asset or risk level, which can be seen as a measure of relevant economic substance and activity.  For trading activity, where less than 50% of the profits relating to an asset or risk are attributable UK SPFs, such profits are exempt. For non-trade finance profits, an exemption will only apply if none of the relevant SPFs are carried out in the UK.  In addition, the rules apply a business premises condition in relation to trading profits and intra-group non-trading finance profits. Certain treatments can only apply if the business of the CFC is wholly or mainly carried on from premises in its territory of residence, to be occupied with a degree of permanence