[259BD Chargeable companies in respect of CFCs and foreign CFCs]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[259BD  Chargeable companies in respect of CFCs and foreign CFCs]

[(1)     This section has effect for the purposes of this Part.

(2)     Subsections (3) to (7) apply where an amount of income arises to an entity (“C”) that is a CFC, a foreign CFC or both and all or part of that amount (the “relevant income”)—

(a)     is not ordinary income of C under section 259BC, or

(b)     arises as a result of a payment or quasi-payment under, or in connection with, a financial instrument or hybrid transfer arrangement and—

(i)     is (disregarding subsection (4)) ordinary income of C under section 259BC for a taxable period, but

(ii)     under taxed.

(3)     The following steps determine whether, and to what extent, the relevant income is “ordinary income” of a chargeable company in relation to the CFC charge or a foreign CFC charge.

Step 1
ٱٱԱ—

(a)     whether any of the relevant income is brought into account in calculating C's chargeable profits for the purposes of the CFC charge or a foreign CFC charge, and

(b)     if so, the amount of the relevant income that is so brought into account for the purposes of each relevant charge.
If none of the relevant

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