SCHEDULE 24 Assumptions for Calculating Chargeable Profits, Creditable Tax and Corresponding United Kingdom Tax of Foreign Companies

SCHEDULE 24 Assumptions for Calculating Chargeable Profits, Creditable Tax and Corresponding United Kingdom Tax of Foreign Companies

Section 747(6)

General

1

(1)     The company shall be assumed to be resident in the United Kingdom.

(2)     Nothing in sub-paragraph (1) above requires it to be assumed that there is any change in the place or places at which the company carries on its activities.

(3)     For the avoidance of doubt, it is hereby declared that, if any sums forming part of the company's profits for an accounting period have been received by the company without any deduction of or charge to tax [and have been so received by virtue of [section 1279 of CTA 2009]] the effect of the assumption in sub-paragraph (1) above is that those sums are to be brought within the charge to tax for the purposes of calculating the company's chargeable profits or corresponding United Kingdom tax.

[(3A)     In any case where—

(a)     it is at any time necessary for any purpose of Chapter IV of Part XVII to determine [in the case of any person] the chargeable profits of the company for an accounting period, and

(b)     at that time—

[(i)     it has not been established

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