»Ê¹ÚÌåÓýapp

This applies for relevant accounting periods beginning on or after 1 January 2013.

Chapter 12 - Low profits Exemption

»Ê¹ÚÌåÓýapp low profits exemption (TIOPA10/Part 9A/CH12) provides an entity-level exemption for CFCs with low levels of profits (broadly £500,000 or under) in an accounting period that accordingly represent a low risk to the UK tax base.

»Ê¹ÚÌåÓýapp exemption is subject to a number of safeguards against possible avoidance activity.

Chapter 12 is modified to apply to foreign PEs by CTA09/Part 2/CH3A/S18IB that omits the £50,000 accounting profit limit in TIOPA10/Part9A/S371LB(2), and the £50,000 non-trading income and £500,000 total accounting profit limits in S371LB(4) as foreign PE profits are attributed under treaty principles rather than a calculation of accounting profits. »Ê¹ÚÌåÓýapp group mismatch anti-avoidance provision in S371LC(6) is also omitted as it is not relevant because it only applies where S371LB(2) and (4) are applicable.

»Ê¹ÚÌåÓýapp detailed rules for the application of Chapter 12 can be found