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Legislation
Taxation (International and Other Provisions) Act 2010

Chapter 2 The CFC charge

  • Section 371BA Introduction to the CFC charge
  • Section 371BB The CFC charge gateway
  • Section 371BC Charging the CFC charge
  • Section 371BD Chargeable companies
  • Section 371BE Companies which are managers of offshore funds etc
  • Section 371BF Companies which are participants in offshore funds
  • Section 371BG Companies holding shares as trading assets etc
  • Section 371BH Companies carrying on BLAGAB
  • Section 371BI Banking companies
  1. Chapter 2 · The CFC charge
  2. Introduction to the CFC charge

Section 371BA | Introduction to the CFC charge

From legislation.gov.uk

(1)The CFC charge is charged in relation to accounting periods of CFCs in accordance with section 371BC.

(2)Section 371BC applies in relation to a CFC's accounting period if (and only if)—

(a)the CFC has chargeable profits for the accounting period, and

(b)none of the exemptions set out in Chapters 10 to 14 applies for the accounting period.

(3)A CFC's chargeable profits for an accounting period are its assumed taxable total profits for the accounting period determined on the basis—

(a)that the CFC's assumed total profits for the accounting period are limited to only so much of those profits as pass through the CFC charge gateway, and

(b)that amounts are to be relieved against the assumed total profits at step 2 in section 4(2) of CTA 2010 only so far as it is just and reasonable for them to be so relieved having regard to paragraph (a).

(4)“The CFC charge gateway” is explained in section 371BB.

(5)Subsection (3) is subject to section 371SB(7) and (8) (which relates to settlement income included in a CFC's chargeable profits).

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