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13.3. CFC and Similar Regimes

A resident company is required to include income of a foreign subsidiary in its taxable income, if such foreign subsidiary constitutes a CFC, subject to following conditions:

  • The resident company, alone or together with other group companies, individual owners, controls the foreign company;
  • The subsidiary's financial assets represent on average more than 10% of the its total assets in a tax year; and
  • The subsidiary is subject to a 'substantially lower tax' than under the tax laws of Greenland.

CFC income generally includes passive and financial income.