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INTM254450 | Controlled Foreign Companies: exemptions - excluded countries: Contents

From HM Revenue & Customs · International Manual

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.

The 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. The new guidance can be found at INTM190000 onwards.

Contents14 entries

  1. INTM254460Controlled Foreign Companies: exemptions - excluded countries: The excluded countries’ exemption
  2. INTM254470Controlled Foreign Companies: exemptions - excluded countries: Purpose of the list
  3. INTM254480Controlled Foreign Companies: exemptions - excluded countries: Terms of List (schedule)
  4. INTM254490Controlled Foreign Companies: exemptions - excluded countries: Meaning of ‘Resident’
  5. INTM254500Controlled Foreign Companies: exemptions - excluded countries: Income and gains requirement
  6. INTM254510Controlled Foreign Companies: exemptions - excluded countries: Commercially quantified income
  7. INTM254520Controlled Foreign Companies: exemptions - excluded countries: Non-local source income
  8. INTM254530Controlled Foreign Companies: exemptions - excluded countries: Meaning of ‘gross amount’ and ‘income’ and ‘gains’
  9. INTM254540Controlled Foreign Companies: exemptions - excluded countries: Permanent establishment income
  10. INTM254550Controlled Foreign Companies: exemptions - excluded countries: Permanent establishment income treated as local source
  11. INTM254560Controlled Foreign Companies: exemptions - excluded countries: Inclusion of non-local source income in permanent establishment income
  12. INTM254570Controlled Foreign Companies: exemptions - excluded countries: Banks and Insurance Companies
  13. INTM254580Controlled Foreign Companies: exemptions - excluded countries: List of excluded countries
  14. INTM254590Controlled Foreign Companies: exemptions - excluded countries: Application of non-local source income rules to permanent establishment income: examples