Part 1 Controlled Foreign Companies

SCHEDULE 20 Controlled Foreign Companies and Foreign Permanent Establishments

Section 180

Part 1 Controlled Foreign Companies

1

After Part 9 of TIOPA 2010 insert—

“Part 9A
Controlled Foreign Companies
Chapter 1
Overview
371AA Overview of Part

(1)     A charge (“the CFC chargeâ€) is charged under this Part on UK resident companies which have certain interests in CFCs.

(2)     The CFC charge is charged by reference to the chargeable profits of CFCs.

(3)     A “CFC†is a non-UK resident company which is controlled by a UK resident person or persons (but see subsection (6)).

(4)     Chapter 2 sets out the basic details of the CFC charge, including—

(a)     the CFC charge gateway (through which profits of a CFC must pass in order to be chargeable profits), and

(b)     the steps to be taken for charging the CFC charge.

(5)     Chapter 2 is supplemented by Chapters 3 to 17; in particular—

(a)     Chapter 3 sets out how to determine which (if any) of Chapters 4 to 8 apply in relation to the profits of a CFC,

(b)     so far as applicable, Chapters 4 to 8 set out how to determine which profits (if any) of a CFC pass through the CFC charge gateway, with—

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