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Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading How are the apportionments to be made?

  • Section 371QC The basic rules
  • Section 371QD Apportionments to be made in proportion to shareholding
  • Section 371QE Indirect shareholdings
  • Section 371QF Variable shareholdings
  • Section 371QG Anti-avoidance
  1. How are the apportionments to be made?
  2. Apportionments to be made in proportion to shareholding

Section 371QD | Apportionments to be made in proportion to shareholding

From legislation.gov.uk

(1)If conditions X to Z in section 371QC are met, apply subsections (2) and (3) to each relevant person.

(2)Determine the percentage (“P%”) of the issued ordinary shares in the CFC represented by the relevant person's relevant interest.

(3)P% of the CFC's chargeable profits and P% of the CFC's creditable tax is then apportioned to the relevant person.

(4)This section is supplemented by sections 371QE and 371QF.

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