INTM254450 - Controlled Foreign Companies: exemptions - excluded countries: Contents
This guidance applies for accounting period before 1 January 2013 and refers to the legislation at Chapter IV Part XVII of the Income and Corporation Taxes Acts 1988, under the old Controlled Foreign Companies (CFC) rules.
The current rules for CFCs are contained in Part 9A, Taxation (International and Other Provisions) Act 2010. This legislation is effective for accounting periods of CFCs beginning on or after 1 January 2013. The new guidance can be found at INTM190000 onwards.
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INTM254460The excluded countries' exemption
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INTM254470Purpose of the list
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INTM254480Terms of list (schedule)
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INTM254490Meaning of 'resident'
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INTM254500Income and gains requirement
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INTM254510Commercially quantified income
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INTM254520Non-local source income
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INTM254530Meaning of 'gross amount' and 'income' and 'gains'
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INTM254540Permanent establishment income
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INTM254550Permanent establishment income treated as loacl source
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INTM254560Inclusion of non-local source income in permanent establishment income
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INTM254570Banks and insurance companies
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INTM254580List of excluded countries
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INTM254590Application of non-local source income rules to permanent establishment income