Apportionment of Profits and Creditable Tax and Assessment of Liability

ICTA88/S747(3) and (4) and ICTA88/S754(2) ICTA

Where an overseas company falls within the definition of a controlled foreign company at ICTA/S747(1) and none of the exemptions at ICTA88/S748 applies United Kingdom interests must apportion the chargeable profits and creditable tax of the company among the persons with an interest in it.

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