Related Commentary  

Notes

Note modified version of s. 725(1) in cases where FA 2012, Sch. 20, para. 50(9) provides for the amendments made by FA 2012, Sch. 20, para. 22 to be ignored.


725(1)  This section applies if–

(a)under Part 9A of TIOPA 2010 (controlled foreign companies), the CFC charge is charged in relation to a CFC's accounting period,

(b)an amount of income is treated as arising to an individual under section 721 for a tax year, and

(c)the income mentioned in section 721(2) is or includes a sum forming part of the CFC's chargeable profits for that accounting period.

725(2)  The amount of income so treated is reduced by–

S × CA
CP

where–

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