[INTM245400] Controlled Foreign Companies: Management and collection of a CFC charge and reliefs available against a CFC charge: Relief against a sum charged on a chargeable company
Relief against a sum charged on a chargeable company
CFC accounting periods beginning on or after 8 July 2015
In respect of CFC's that have an accounting period beginning on or after 8 July 2015, it is not possible for the chargeable company to make a claim under TIOPA10/S371UD(2) for relief in respect of relevant allowances to be set against the sum charged at step 5 in TIOPA10/S371BC(1).
The purpose of this amendment in F(No 2)A15/S36 is to ensure that UK tax is actually paid on profits that have been diverted from the UK to a CFC and that relevant allowances do not reduce or eliminate this amount.