Commentary

D4.420 CFCs and the meaning of chargeable profits

Corporate tax
Corporate tax | Commentary

D4.420 CFCs and the meaning of chargeable profits

Corporate tax | Commentary

Determining chargeable profits for CFCs

D4.420 CFCs and the meaning of chargeable profits

If none of the full exemptions (as detailed in D4.410–D4.415) apply, it is necessary to determine the CFCs chargeable profits which are subject to the CFC charge. A CFCs chargeable profits are its assumed taxable total profits for the relevant accounting period on the basis that:

  1.  

    (a)     its assumed total profits for the accounting period are limited to those profits which pass through the CFC gateway (see D4.421), and

  2.  

    (b)     amounts which can be relieved against a company's income1 are done so on a just and

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial