»Ê¹ÚÌåÓýapp

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.

»Ê¹ÚÌåÓýapp de minimis exemption

ICTA88/S748(1)(d)

Under ICTA88/S748(1)(d) no apportionment is due in respect of an accounting period of a controlled foreign company in which its chargeable profits do not exceed £50,000. If the accounting period is less than twelve months the amount of £50,000 is proportionally reduced. An apportionment will be due, if none of the exemptions applies, regardless of however small the amount by which the de minimis limit is exceeded.