INTM255600 - Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: 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.

1. INTM255610

   Introduction
2. INTM255620

   Definition of chargeable profits
3. INTM255630

   Assumed residence and apportionment
4. INTM255640

   Place of trade
5. INTM255650

   Transactions with associates
6. INTM255660

   Foreign exchange and currency account
7. INTM255670

   Effect on other liabilities
8. INTM255680

   Close company and group provisions
9. INTM255690

   Claims assumed to be made
10. INTM255700

    Disclaimer and variation of reliefs and claims, or elections that are not reliefs
11. INTM255710

    Form of disclaimer, etc
12. INTM255720

    Majority interest
13. INTM255730

    Intangible fixed assets
14. INTM255740

    Time limit
15. INTM255750

    Capital allowances
16. INTM255760

    Losses in pre-apportionment accounting period
17. INTM255770

    Time limit
18. INTM255780

    Form of claim
19. INTM255790

    Effect of claim
20. INTM255800

    Limitations on scope of ICTA88/SCH24/PARA9
21. INTM255810

    Reconstruction without change of ownership
22. INTM255820

    Unremittable income
23. INTM255830

    Creditable tax