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Contents

Official guidance
International Manual

INTM255850 · Controlled Foreign Companies: apportionment of chargeable profits and creditable tax

  • INTM255860 · Apportionment and assessment
  • INTM255870 · Interaction with ICTA88/S739
  • INTM255880 · Substantial interest requirement
  • INTM255890 · Interests in a controlled foreign company
  • INTM255900 · ‘Entitled to acquire’ and ‘entitled to secure’
  • INTM255910 · Indirect interests
  • INTM255920 · Relevant interests
  • INTM255930 · Interests by virtue of ordinary shares alone
  • INTM255940 · Calculation of interest based on ordinary shares
  • INTM255950 · Adjustments for changes in ordinary shareholdings
  • INTM255960 · Example of relevant interests and interests by virtue of ordinary shares alone
  • INTM255970 · Interests other than by virtue of ordinary shares alone
  • INTM255980 · Determination of apportionment by the Commissioners of HM Revenue & Customs
  1. Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Contents
  2. Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Indirect interests

INTM255910 | Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Indirect interests

From HM Revenue & Customs · International Manual

A person may hold an indirect interest in a controlled foreign company. ICTA88/S749B(5)-(7) provides that where a company (B) has an interest in another company (C) and another company (A), or two or more persons together, has an interest in company B, company A has the same interest in C as does company B. When two or more persons jointly have a beneficial interest in a company they are treated as having the same interest in equal shares.

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