Where the provisions of Chapter IV apply to a controlled foreign company, ICTA88/S747(3) requires that the chargeable profits and creditable tax of the company should be apportioned (see INTM255850). ‘Creditable tax’ is defined as the aggregate of the following amounts:
(1)The amount of any double taxation relief for foreign tax which would be available against Corporation Tax on income under the rules in TIOPA10/Part 2. This is calculated on the basis of the assumption in ICTA88/SCH24 and as if the controlled foreign company were liable to Corporation Tax on its chargeable profits.
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