SCHEDULE 15 Controlled Foreign Companies

SCHEDULE 15 Controlled Foreign Companies

Section 48

Imputation of chargeable profits and creditable tax of controlled foreign companies

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(1)     Section 747 of ICTA (imputation of chargeable profits and creditable tax of controlled foreign companies) is amended as follows.

(2)     After subsection (3) insert—

“(3A)     In the case of an apportionment to a company resident in the United Kingdom which has made an application under section 751A which has been granted, subsection (3) above has effect subject to that section.â€

(3)     After subsection (5) insert—

“(5A)     Where the resident company has made an application under section 751A which has been granted, it shall be assumed for the purposes of subsection (5) above that—

(a)     each of the persons who are connected or associated with the resident company has made an application under that section to the same effect, and

(b)     all the applications have been granted.â€

Residence

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In section 749 of ICTA (residence), insert at the end—

“(10)     For the purposes of subsection (8) and (9) above, the effect of any application under section 751A shall be disregarded.â€

Elections and designations under section 749: supplementary provisions

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In section 749A of ICTA (elections and designations

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