Part 1 Exemptions for Companies with Limited UK Connection
Finance Act 2011 (2011 c 11) | Legislation

SCHEDULE 12 Controlled Foreign Companies

Section 47

Part 1 Exemptions for Companies with Limited UK Connection

1

(1)     Section 748 of ICTA (cases where apportionment of chargeable profits and creditable tax under section 747(3) does not apply) is amended as follows.

(2)     In subsection (1), in paragraph (b) for “that Schedule†substitute “Schedule 25â€.

(3)     After that paragraph insert—

“(ba)     the company is exempt for that period by virtue of Part 2A of that Schedule (exemption for trading companies with limited UK connection); or

(bb)     the company is exempt for that period by virtue of Part 2B of that Schedule (exemption for companies exploiting intellectual property with limited UK connection); orâ€.

2

After section 751AA of that Act insert—

“751AB Reduction in chargeable profits: failure to qualify for exemptions

(1)     This section applies if—

(a)     an apportionment under section 747(3) would fall to be made as regards an accounting period (“the relevant accounting periodâ€) of a controlled foreign company,

(b)     but for a relevant failure, section 748(1)(ba) or (bb) would have prevented such an apportionment, and

(c)     a company resident in the United Kingdom (“the UK resident companyâ€) has a relevant interest in the controlled foreign company in

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