INTM164235 - UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 2 December 2004 - the ADP mixer cap

This legislation was repealed in relation to accounting periods of controlled foreign companies beginning on or after 1 July 2009.

ICTA88/S801(2A) applied the mixer cap to dividends received by UK companies on or after 31 March 2001 (INTM164220). FA05/S89 introduced an additional clause to ICTA88/S801(2A) applying ICTA88/S801(2B) where the relevant dividend is an ADP dividend of a CFC. ICTA88/S801(2B) introduced in the place of the 2001 mixer cap a new formula to be used, the ADP mixer cap.

»Ê¹ÚÌåÓýapp formula is D/1 - X x X where:

D is the amount of the dividend

X is the maximum relievable rate, expressed as a decimal fraction

»Ê¹ÚÌåÓýapp maximum relievable rate is the rate of corporation tax in force when the dividend was paid.

»Ê¹ÚÌåÓýapp ADP mixer cap is substituted for the mixer cap in ICTA88S799(1A) and as a result there are no other amendments to the subsequent calculations.