»Ê¹ÚÌåÓýapp

»Ê¹ÚÌåÓýappre are no special rules for controlled foreign companies and IRUs. »Ê¹ÚÌåÓýapp general controlled foreign companies rules will apply. For more information about controlled foreign companies see INTM200000 onwards.

If income from IRUs would form part of the chargeable profits of a UK company, the income will form part of the chargeable profits of a controlled foreign company that could be apportioned.

Exempt activities test

»Ê¹ÚÌåÓýapp granting of an IRU is the leasing of a property or right and falls within the definition of investment business (INTM205070). »Ê¹ÚÌåÓýapp fact that the business, if carried on in the UK, would be taxed under Case I of Schedule D makes no difference. »Ê¹ÚÌåÓýapp controlled foreign company is still deemed to carry on an investment business outside the terms of the exempt activities test (INTM205010).