INTM255600 - Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: 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.

  1. INTM255610
    Introduction
  2. INTM255620
    Definition of chargeable profits
  3. INTM255630
    Assumed residence and apportionment
  4. INTM255640
    Place of trade
  5. INTM255650
    Transactions with associates
  6. INTM255660
    Foreign exchange and currency account
  7. INTM255670
    Effect on other liabilities
  8. INTM255680
    Close company and group provisions
  9. INTM255690
    Claims assumed to be made
  10. INTM255700
    Disclaimer and variation of reliefs and claims, or elections that are not reliefs
  11. INTM255710
    Form of disclaimer, etc
  12. INTM255720
    Majority interest
  13. INTM255730
    Intangible fixed assets
  14. INTM255740
    Time limit
  15. INTM255750
    Capital allowances
  16. INTM255760
    Losses in pre-apportionment accounting period
  17. INTM255770
    Time limit
  18. INTM255780
    Form of claim
  19. INTM255790
    Effect of claim
  20. INTM255800
    Limitations on scope of ICTA88/SCH24/PARA9
  21. INTM255810
    Reconstruction without change of ownership
  22. INTM255820
    Unremittable income
  23. INTM255830
    Creditable tax