INTM254450 - Controlled Foreign Companies: exemptions - excluded countries: 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.
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INTM254460»Ê¹ÚÌåÓýapp excluded countries' exemption
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INTM254470Purpose of the list
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INTM254480Terms of list (schedule)
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INTM254490Meaning of 'resident'
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INTM254500Income and gains requirement
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INTM254510Commercially quantified income
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INTM254520Non-local source income
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INTM254530Meaning of 'gross amount' and 'income' and 'gains'
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INTM254540Permanent establishment income
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INTM254550Permanent establishment income treated as loacl source
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INTM254560Inclusion of non-local source income in permanent establishment income
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INTM254570Banks and insurance companies
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INTM254580List of excluded countries
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INTM254590Application of non-local source income rules to permanent establishment income