Commentary

D4.415 CFCs: tax exemption

Corporate tax
Corporate tax | Commentary

D4.415 CFCs: tax exemption

Corporate tax | Commentary

D4.415 CFCs: tax exemption

A company is exempt from the CFC charge if the local tax amount is at least 75% of the corresponding UK tax1.

The local tax amount is the tax paid in the CFC's territory for that accounting period in respect of the CFC's local chargeable profits (subject to any specific deductions required2). The corresponding UK tax is the amount of corporation tax which would be charged in respect of the CFC's assumed taxable total profits for the accounting period (applying the assumptions detailed at D4.421) but without taking into account any double taxation relief in respect

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