The corresponding UK tax is the amount of corporation tax which would be chargeable in respect of the CFC's ‘assumed taxable total profits’ for the accounting period subject to the assumptions and adjustments required by applying the ‘corporation tax assumptions’. Assumed taxable total profits and the corporation tax assumptions (including the assumption that the CFC is resident in the United Kingdom) are explained in Chapter 19 (see INTM239000). There are also assumptions and adjustments required by TIOPA10/S371NE(2).

Assumptions and Adjustments Required by TIOPA10/S371NE(2)

The assumptions and adjustments required under TIOPA10/S371NE(2) for the calculation of the corresponding UK tax of a CFC are as follows:

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