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Contents

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. Variable shareholdings

Section 371QF | Variable shareholdings

From legislation.gov.uk

(1)This section applies if the percentage of the issued ordinary shares in the CFC represented by a relevant person's relevant interest varies during the accounting period.

(2)That percentage is taken to be the percentage equal to the sum of the relevant percentages for each holding period.

(3)“Holding period” means a part of the accounting period during which the percentage of the issued ordinary shares in the CFC represented by the relevant person's relevant interest remains the same.

(4)“Relevant percentage”, in relation to a holding period, means the percentage given by the following formula—

Formula

P×HA

where—

P is the percentage of the issued ordinary shares in the CFC represented by the relevant person's relevant interest during the holding period,

H is the number of days in the holding period, and

A is the number of days in the accounting period.

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