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INTM255850 | Controlled Foreign Companies: apportionment 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.

Contents13 entries

  1. INTM255860Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Apportionment and assessment
  2. INTM255870Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Interaction with ICTA88/S739
  3. INTM255880Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Substantial interest requirement
  4. INTM255890Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Interests in a controlled foreign company
  5. INTM255900Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: ‘Entitled to acquire’ and ‘entitled to secure’
  6. INTM255910Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Indirect interests
  7. INTM255920Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Relevant interests
  8. INTM255930Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Interests by virtue of ordinary shares alone
  9. INTM255940Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Calculation of interest based on ordinary shares
  10. INTM255950Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Adjustments for changes in ordinary shareholdings
  11. INTM255960Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Example of relevant interests and interests by virtue of ordinary shares alone
  12. INTM255970Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Interests other than by virtue of ordinary shares alone
  13. INTM255980Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Determination of apportionment by the Commissioners of HM Revenue & Customs