64 Controlled foreign companies
Finance Act 2008 (2008 c 9) | Legislation

64  Controlled foreign companies

(1)     Chapter 4 of Part 17 of ICTA (controlled foreign companies) is amended as follows.

(2)     In section 747 (imputation of chargeable profits of controlled foreign companies)—

(a)     in subsection (6), before “and” at the end of paragraph (a) insert—

“(aa)     any reference in this Chapter to its chargeable profits for an accounting period includes (subject to subsections (7) to (9)) income which accrues during that accounting period to the trustees of a settlement in relation to which the company is a settlor or a beneficiary;”, and

(b)     after that subsection insert—

“(7)     Where there is more than one settlor or beneficiary in relation to the settlement mentioned in subsection (6)(aa), the income is to be apportioned between the company and the other settlors or beneficiaries on a just and reasonable basis.

(8)     Where income within subsection (6)(aa) is included in the chargeable profits of a company, any dividend or other distribution received by the company which derives from that income is not included in the chargeable profits of the company to the extent that it is so

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