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

Contents23 entries

  1. INTM255610Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Introduction
  2. INTM255620Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Definition of chargeable profits
  3. INTM255630Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Assumed residence and apportionment
  4. INTM255640Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Place of trade
  5. INTM255650Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Transactions with associates
  6. INTM255660Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Foreign exchange and currency account
  7. INTM255670Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Effect on other liabilities
  8. INTM255680Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Close company and group provisions
  9. INTM255690Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Claims assumed to be made
  10. INTM255700Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Disclaimer and variation of reliefs and claims, or elections that are not reliefs
  11. INTM255710Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Form of disclaimer, etc
  12. INTM255720Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Majority interest
  13. INTM255730Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Time limit
  14. INTM255740Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Intangible fixed assets
  15. INTM255750Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Capital allowances
  16. INTM255760Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Losses in pre-apportionment accounting period
  17. INTM255770Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Time limit
  18. INTM255780Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Form of claim
  19. INTM255790Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Effect of claim
  20. INTM255800Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Limitations on scope of ICTA88/SCH24/PARA9
  21. INTM255810Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Reconstruction without change of ownership
  22. INTM255820Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Unremittable income
  23. INTM255830Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Creditable tax