The CFC rules do not apply when:
- less than 1/3 of the total income qualifies as passive income (art. 185/2, §4, par. 1, 2nd stripe, BITC 92);
- the CFC is a financial enterprise and its passive income comes for one-third or less from transactions with the taxpayer or with the taxpayer's associated entities (art. 185/2, § 4, par. 1, 3rd stripe, BITC 92).