Definitions: lower level of taxation

Introduction

By definition a company cannot be a ‘controlled foreign company’ unless it is subject to a lower level of taxation in the territory in which it is resident (see INTM254400). If this condition does not apply for a particular accounting period then the company is not a controlled foreign company in that period and no apportionment under Chapter IV falls to be made.

Need help? Get subscribed!

To subscribe to this content, simply call 0800 231 5199

We can create a package that’s catered to your individual needs.

Or book a demo to see this product in action.