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13.3. CFC and Similar Regimes

The corporate tax ('CIT') tax code contains specific Controlled Foreign Company rules.

A resident company owning, directly or indirectly, at least 25% in the capital, voting rights or rights in income or estate of a controlled foreign entity ('CFE') is subject to tax on its allocable share of the CFE's net profit or income. For computing the 25% threshold, the capital and rights owned, directly or indirectly, by related parties are also considered.

Several rules, which are based on the nature of the activity and whether the activity is predominantly directed to the Cape Verdean market, may result in the non-imputation of profits or income.