Commentary

E1.1116 Charge under ITA 2007, s 727—reduction where person abroad is a CFC

Personal and employment tax

E1.1116 Charge under ITA 2007, s 727—reduction where person abroad is a CFC

E1.1116 Charge under ITA 2007, s 727—reduction where person abroad is a CFC

Where a non-UK resident company is controlled by persons resident in the UK, the profits of that company for an accounting period may, if certain conditions are met, be apportioned to its UK shareholders. In such a case, the non-resident company is designated a controlled foreign company (CFC), and the amounts of its profits apportioned to any company resident in the UK are charged to corporation tax on that company1. See Division D4.4 for the CFC rules.

The rules at E1.1111 apply (with the necessary modifications) where income

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