INTM255850 - Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Contents

This guidance applies for accounting period before 1 January 2013 and refers to the legislation at Chapter IV Part XVII of the Income and Corporation Taxes Acts 1988, under the old Controlled Foreign Companies (CFC) rules.

»Ê¹ÚÌåÓýapp current rules for CFCs are contained in Part 9A, Taxation (International and Other Provisions) Act 2010. This legislation is effective for accounting periods of CFCs beginning on or after 1 January 2013. »Ê¹ÚÌåÓýapp new guidance can be found at INTM190000 onwards.

  1. INTM255860
    Apportionment and assessment
  2. INTM255870
    Interaction with ICTA88/S739
  3. INTM255880
    Substantial interest requirement
  4. INTM255890
    Interests in a controlled foreign company
  5. INTM255900
    Entitled to acquire' and 'entitled to secure'
  6. INTM255910
    Indirect interests
  7. INTM255920
    Relevant interests
  8. INTM255930
    Interests by virtue of ordinary shares alone
  9. INTM255940
    Calculation of interest based on ordinary shares
  10. INTM255950
    Adjustments for changes in ordinary shareholdings
  11. INTM255960
    Example of relevant interests and interests by virtue of ordinary shares alone
  12. INTM255970
    Interests other than by virtue of ordinary shares alone
  13. INTM255980
    Determination of apportionment by Commissioners of HM Revenue and Customs