Broadly speaking, a CFC charge arises  in respect of any trading profits where 50% of the relevant SPFs in relation to an asset or risk which generate those profits are carried out in the UK. For trading finance profits (banking and insurance) a charge will arise where the CFC is overcapitalised with funds received from UK connected persons (UK group companies). For non-trade finance profits, a charge will arise on profits relating to assets or risks attributable to UK SPFs , profits generated using UK connected capital (from UK group companies), arrangements in lieu of dividends to the UK and certain leasing arrangements. For  intra-group financing arrangements, a charge arises on profits if any of the related SPFs are in the UK, if the CFC is overcapitalised with funds from the UK, or if profits are otherwise diverted from the UK.  Entity level exemptions can apply in relation to low profits (de minimis threshold - less than  £50k profits in a 12 month period, or less than  £500k profits so long as passive interest income does not exceed  £50k in that period); low profit margins (where accounting profits are not more than 10% of relevant operating expenses); high effective tax rates (at least 75% of UK ETR) and excluded countries with similar tax base/rate to UK; subject to an anti-avoidance test and limits on passive income; Temporary exemption period for certain acquisitions, subject to anti-avoidance conditions;