[INTM239300] Controlled Foreign Companies: Assumed Taxable Total Profits, Assumed Total Profits and the Corporation Tax Assumptions: Corporation Tax Assumptions
The corporation tax assumptions are the assumptions that are set out in TIOPA10/Part9A/S371SD to 371SR. Broadly speaking, the CFC's profits are calculated on the assumption that the CFC is UK resident in the accounting period. Certain additional assumptions provide continuity of treatment for reliefs and restrict opportunities for avoidance.
Brief overview of sections:
•TIOPA10/S371SD provides that the CFC is assumed to be UK resident from the beginning of the CFC's first accounting period (i.e. the CFC's accounting period which begins when it becomes a CFC) and that it is assumed to be within the charge to corporation tax.