5(1A) Except as provided in paragraph 8 below, the provisions of this Part of this Schedule apply in relation to a company which is resident in an EEA territory in the same way as they apply in relation to a company which is resident elsewhere.
5(2) In the case of a controlled foreign company–
(a)which is, by virtue of section 749(5), presumed to be resident in a territory in which it is subject to a lower level of taxation, and
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