Commentary

D4.801A Exclusions

Corporate tax
Corporate tax | Commentary

D4.801A Exclusions

Corporate tax | Commentary

D4.801A Exclusions

The exemption cannot apply in certain situations. The rules were changed for accounting periods commencing on or after 1 January 2013 to reflect the new CFC regime (see Division D4.4).

Accounting periods commencing on or after 1 January 2013

The exemption cannot apply:

  1.  

    (a)     to 'diverted profits' that are included within the adjusted relevant profits (ie profits computed without reference to chargeable gains or losses). In such situations the diverted profits are left out of account1. Diverted profits are those profits that pass through what is referred to as the 'diverted profits' gateway, which is determined (with necessary modifications) using essentially the same principles as those that apply to the CFC gateway (D4.425), with the exception of the solo consolidation rules (D4.430) on

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