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.

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