Definition – ICTA88/S751(6)

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.

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.