Commentary

D4.437 CFC's and creditable tax

Corporate tax
Corporate tax | Commentary

D4.437 CFC's and creditable tax

Corporate tax | Commentary

D4.437 CFC's and creditable tax

In determining the CFC charge as set out in D4.435, after step 1 it is then necessary to calculate and apportion the creditable tax for that period1. The amount of creditable tax so calculated is then apportioned among the relevant persons for the purposes of step 3 (D4.438).

The amount of a CFC's creditable tax for an accounting period is the total of the following amounts2:

  1.  

    •     the amount of any double taxation relief which would be available in respect of any income included or represented in the CFC's chargeable profits for the accounting period

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