INTM255850 - Controlled Foreign Companies: apportionment 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. INTM255860

   Apportionment and assessment
2. INTM255870

   Interaction with ICTA88/S739
3. INTM255880

   Substantial interest requirement
4. INTM255890

   Interests in a controlled foreign company
5. INTM255900

   Entitled to acquire' and 'entitled to secure'
6. INTM255910

   Indirect interests
7. INTM255920

   Relevant interests
8. INTM255930

   Interests by virtue of ordinary shares alone
9. INTM255940

   Calculation of interest based on ordinary shares
10. INTM255950

    Adjustments for changes in ordinary shareholdings
11. INTM255960

    Example of relevant interests and interests by virtue of ordinary shares alone
12. INTM255970

    Interests other than by virtue of ordinary shares alone
13. INTM255980

    Determination of apportionment by Commissioners of HM Revenue and Customs