INTM255880 - Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Substantial interest requirement
ICTA88/S747(5) ICTA 1988
Where chargeable profits of a controlled foreign company are apportioned to a United Kingdom resident company, no assessment may be made in respect of those profits unless the aggregate of the following amounts is at least 25% of the total chargeable profits of the controlled foreign company. The amounts to be aggregated are:
- the amount of the chargeable profits which have been apportioned to the resident company, and
- the amount of the chargeable profits which have been apportioned to persons (whether corporate or individual) who are connected or associated with the resident company. (See INTM254410)