INTM255150 - Controlled Foreign Companies: exemptions - the motive test: 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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INTM255160Introduction to the motive test
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INTM255170»Ê¹ÚÌåÓýapp conditions of the motive test
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INTM255180Â transactions reducing United Kingdom tax
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INTM255190Â statutory definition
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INTM255200are the results of the transaction(s) reflected in the controlled foreign company's profits for the accounting period?
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INTM255210Â reduction in United Kingdom tax?
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INTM255220Â reduction in United Kingdom tax more than minimal?
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INTM255230»Ê¹ÚÌåÓýapp transaction leg of the motive test: motive element
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INTM255240»Ê¹ÚÌåÓýapp diversion of profits leg of the motive test
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INTM255250Â statutory definition
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INTM255260are there receipts reflected in the controlled foreign company's profits for an accounting period?
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INTM255270Controlled Foreign Companies: exemptions - the motive test: »Ê¹ÚÌåÓýapp diversion of profits leg of the motive test: would it be reasonable to suppose that the whole or a substantial part of the receipts would have been received by a United Kingdom person?
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INTM255280related company
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INTM255290Â United Kingdom company
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INTM255300Â would the United Kingdom person have paid more, or been entitled to less relief from, united Kingdom tax?
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INTM255310motive element
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INTM255320Application of motive test: overview
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INTM255330Application of motive test: 'marginal and isolated failure' of exempt activities and excluded countries exemptions
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INTM255340Application of motive test: newly-established overseas business
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INTM255350Application of motive test: incorporation of foreign branch
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INTM255360Application of motive test: United Kingdom takeover of overseas group - 'period of grace'
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INTM255370Application of motive test: background
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INTM255380Application of motive test: 21 March 2000 example
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INTM255390Application of motive test: avoidance of United Kingdom or foreign tax
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INTM255400Application of motive test: conduit companies
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INTM255410Application of motive test: Venture Capital Limited Partnerships
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INTM255420Application of motive test: loan relationships legislation
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INTM255430Application of motive test: examples - 'marginal and isolated failure' of exempt activities and excluded countries exemptions
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INTM255430Application of motive test: examples - 'marginal and isolated failure' of exempt activities and excluded countries exemptions
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INTM255440Application of motive test: examples - United Kingdom takeover of overseas group
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INTM255450Application of motive test: examples - locally based traders failing the exempt activities test
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INTM255460Application of motive test: examples - intra-group service providers failing the exempt activities test
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INTM255470Application of motive test: examples - controlled foreign company's profits effectively subject to tax in the United Kingdom
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INTM255480Application of motive test: examples - captive insurerance companies
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INTM255490Application of motive test: examples - 'money boxes'
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INTM255500Application of motive test: examples - holding companies