Who needs to keep records?
You must keep records (as set out below) if you are an attributable taxpayer of:
- a controlled foreign company (CFC), or
- a non-resident trust estate.
An attributable taxpayer is a person who:
- alone, or together with associates, has an interest in a CFC or a controlled foreign trust of at least 10% or
- is a transferor of a non-resident trust, or
- is one of the actual controllers of the CFC with an interest of at least 1%.