Section 371SN | Unremittable overseas income
From legislation.gov.uk
(1)For the purposes of Part 18 of CTA 2009 (unremittable overseas income) assume that in section 1274(1)(a), (3) and (4) of that Act references to the United Kingdom are references to the relevant territories.
(2)“The relevant territories” means—
(a)the United Kingdom,
(b)the territory in which the CFC is taken to be resident for the relevant accounting period as determined under Chapter 20, and
(c)any other territory in which the CFC is in fact resident at any time during the relevant accounting period.