40 per cent test

Acceptable distribution policy

Accounting periods straddling 1 July 2009

Long term insurance business/large risk insurance

Transitional provisions

Accounting period

Accounting periods

Beginning on or after 1 January 2013

Generally

Pre-1 January 2012

Transitional provisions

Accounting profits

Adjustments to

Generally

Advance corporation tax

Surrender

Unrelieved surplus set-off

Advances made, meaning

Appeals affecting more than one person

Apportionment of chargeable profits and creditable tax

Anti-avoidance

Anti-avoidance provisions

Basic rules

Generally

In proportion to ordinary shareholdings

Indirect shareholdings

Interest in a company

Interests held by UK resident companies/related persons

Interpretation

Relevant interest, determination

Variable shareholdings

Arbitrage rules

Arrangement, meaning

Arrangements for paying tax on behalf of group members

Assessments

Associated persons

Associated, meaning

Assumed close company

Assumed election

Assumed residence

Background to new rules

Banking and similar business

Banking business profits

Banking business, meaning

Business establishment, meaning

Capital allowances

– see also Capital allowances

Generally

Capital interest, meaning

Captive insurance business

Captive insurance companies (CFC charge gateway), basic rule

Captive insurance companies, motive test

Cell companies

Change of accounting basis, mark to market

Charge (CFC charge)

Accounting period

Basic life insurance and general annuity business (BLAGAB)

Chargeable companies

Chargeable profits

Creditable tax

Determination, series of steps

Gateway

General rules

Generally

Holding shares as trading assets etc.

Imposition

Insurance companies carrying on BLAGAB

Method for making

Offshore fund managers

Offshore funds

Participators in offshore funds

Recovery of sum charges

Relief for relevant allowance

Shares held as trading assets

Charge gateway (CFC charge gateway)

Application of provisions

Captive insurance business

Exempt distribution income

Generally

Group treasury companies

Non-trading finance profits

Profits attributable to UK activities

Solo consolidation

Trading finance profits

Trading or property business profits

Chargeable profits

Apportionment

Assumed taxable total profits, meaning

Assumed total profits, meaning

Assumptions for calculation

Corporation tax assumptions

Dividends

Generally

Just and reasonable apportionments

Commencement of new regime

Common terms

Company reconstructions

Compatibility of national legislation with EU law

Generally

Reference to ECJ, special commissioners' power to make

Restriction of freedom of establishment

Connected persons

Connected, meaning

Control, meaning

Accounting periods, reference to

Accounting test

Economic test

Generally

Legal and economic control

Legal test

Parent undertaking

Subsidiary undertaking

Three mechanical tests

Two or more persons

Corporation tax assumptions

Assumed taxable total profits

Assumed total profits

Capital allowances

Claims and elections

Close company status

Close company, assumed not to be

Designated currency election

Designated currency, elections

Disguised interest

Disguised interest provisions

Double taxation relief

Generally

Group relief

Intangible fixed assets

Leases treated as long funding leases, elections

Long funding leases, election for leases to be treated as

Meaning

Shares accounted for as liabilities

Shares accounted for as liabilities provisions

Tax advantage, arrangements to obtain

Tax advantage, arrangements to secure

UK residence

Unremittable overseas income

Costs of purchasing property

Creditable tax

Apportionment

Generally

Just and reasonable apportionments

Meaning

Deemed lower level of taxation

Definitions

Designated currency election

Designer rate tax provisions

Discovery assessment

Generally

Meaning

Disguised interest

Disguised interest provisions

Distributions received from

Distributive business

Diversion of profits

Diversion of tax

Dividends

Double taxation relief

Election

Enquiry closure notice, meaning

Entity-level exemptions

Excluded territories exemption

Exempt period exemption

Generally

Low profit margin exemption

Low profits exemption

Tax exemption

Euroconversion

Exchange gains and losses

Excluded countries

Accounting periods beginning before 9 July 1998

Accounting periods beginning on or after 9 July 1998

Branch or agency income and gains

Income and gains requirements

Limitation on apportionment

List

Excluded territories exemption

Basic rule

Category A income

Category B income

Category D income

Conditions to be met

Determination of territory of residence

Four categories of income

Generally

Intellectual property condition

Residence in an excluded territory

Threshold amount, meaning

Exempt activities

Accounting period straddling 1 July 2009

Anti-avoidance, reference periods

Banking

Conditions

EEA territory

Exempt holding company, meaning

Generally

Holding companies

Hong Kong and Macao companies

Insurance business

Local holding companies

Qualifying holding companies

Residence territory

Trade investments, advances made and securities

Trustees' income

Ultimate corporate parent, meaning

Exempt period exemption

Adjustment of profits passing through CFC charge gateway

Anti-avoidance provisions

Anti-avoidance rule

Basic rule

Chargeable company condition

Commencement of exempt period

Company tax returns, amendment of

Example

Exempt period condition

Generally

Subsequent period condition

Transitional rules

Exemption from tax

Basic rule

Corresponding UK tax, determination

Designer rate tax provisons, meaning

Generally

Reduction to local tax amount

Exemptions from the rules, limited UK connection

Finance leases

Finance profits

Financial business

Foreign branch exemption regime

Foreign permanent establishments

Freedom of establishment

Gains on disposal of shares

Generally

Gross income, determining

Group mismatch schemes

Group relief

Group treasury companies

Accounting periods beginning before, and ending on or after 20 March 2013

Generally

Hire purchase

Holding companies

Identifying

Incorporated cell companies

Insurance business, meaning

Insurance companies

General insurance business of foreign company accounted for on non-annual basis

Generally

Intangible fixed assets

Intellectual property, exploitation of

Business establishment

Finance income

Generally

Intellectual property business

Interpretation

Other business activities

UK connection

Interests in companies

Interim improvements

Interpretation

Investment business

Leases treated as long funding leases

Leasing plant and machinery, restriction on use of losses

Limited UK connection

Business activities

Business establishment

Finance income

Generally

Gross income

Intellectual property income

UK connection

Loan relationships (qualifying), exemption for profits from

75 per cent exemption

Basic rule

Claims

Conditions to be met

Determination of profits

Exclusions

Full exemption

Funded out of qualifying resources

Generally

Limit on credit

Matched interest

Matched interest, exemption for

Meaning of qualifying loan relationship

Qualifying loan relationship, meaning

Qualifying resources, meaning

Qualifying value of relevant pre-acquisition funds

Local holding companies

Local reinsurance contracts

Long funding leases, election for leases to be treated as

Losses in pre-direction accounting period

Low profit margin exemption

Anti-avoidance rule

Basic rule

Generally

Low profits exemption

Accounting profits for the period

Anti-avoidance provisions

Anti-avoidance rules

Basic rule

Generally

Pre-tax profits

Lower level of taxation

Majority interest, meaning

Management of charge

Appeals affecting more than one person

Application of Taxes Acts

Generally

Just and reasonable apportionments

Recovery of sum charge from other UK resident companies

Relief against sum charged

Maximum reliefs assumed to be claimed

Meaning

Motive test

Non-trading finance profits

Capital investment from the UK

Conditions to be met for profits to pass through gateway

Dividends to UK resident companies, profits paid in lieu of

Five per cent rule

Generally

Incidental

Leases to UK resident companies, profits arising

Meaning

Profits from UK activities

Relevant finance lease

Non-trading finance profits (CFC charge gateway)

Basic rule

Capital investment from the UK

Dividends and distributions to UK resident companies, arrangements in lieu of

Finance leases to UK resident companies

UK activities

Non-trading income

Non-trading income, meaning

Offshore funds

Outstanding capital, meaning

Overview

Overview of new regime

Pre-1 January 2013

40 per cent test

Apportionment of chargeable profits

Charge to tax

Control, meaning

Designer rate regimes

Excluded companies

Excluded countries list

Exempt activities test

Exempt period test

Generally

Limited UK connection test

Motive test

Scope of legislation

Small chargeable profits test

Small relevant profits test

Territory of residence

Premises

Profits attributable to UK activities

Business premises condition

Economic value, exclusion

Exclusion of amounts

Export of goods condition

Generally

Income condition

Intellectual property condition

Management expenditure condition

OECD guidance

Step-by-step approach

Trading profits, exclusion

UK activities a minority of total activities, exclusion

Profits attributable to UK activities (CFC charge gateway)

Anti-avoidance (trading profits), exclusion

Business premises condition (trading profit), exclusion

Economic value, exclusion

Exclusions

Export of goods condition (trading profit), exclusion

Generally

Income condition (trading profit), exclusion

Independent companies' arrangements, exclusion

Intellectual property (trading profit), exclusion

Management expenditure condition (trading profit), exclusion

Steps to be taken

Trading profit

UK activities a minority of total activities, exclusion

Property business profits

Purchase of property, costs deductible

Qualifying resources

Exceptions

Reduction in UK tax

Regulations

Related companies

Related, meaning

Relevant finance leases

Relevant interest rules

Bare trustee, meaning

Generally

Indirect and direct interest, meaning

Interpretation

Relevant interest, meaning

Reliefs

Gains on disposal of shares

Group relief

Trading losses

Residence

Assumed

Basic rule

Corporation tax assumptions

Designations

Determination of territory

Determining

Elections

Generally

Territory

Two or more eligible territories

Self-assessment

Solo consolidation

Solo consolidation (CFC charge gateway), basic rule

Superior holding companies

Surrender of losses

Tax exemption

Calculation of corresponding UK tax

Designer rate tax provisions

Determination

Generally

Reductions to be made to local tax amount

Temporary exemption following certain acquisitions and reorganisations

Beginning of exempt period

Disqualifying relevant transactions

Ending of exempt period

Generally

Interpretation

Territories with a lower level of taxation

Tonnage tax

Tonnage tax companies

Trade investments, meaning

Trading finance profits

An arrangement which would be

Banking business profits

Basic rule

Captive insurance business, profits from

Free assets, meaning

Free capital, meaning

Generally

Loan relationships

Loans from foreign permanent establishments of UK companies

Solo consideration, profits under

Trading finance profits (CFC charge gateway)

Banking business, exclusion

Basic rule

Insurance business, exclusion

Loans from foreign permanent establishments of UK resident companies

Qualifying loan relationships

Trading income, meaning

Trading profits, meaning

Transfer of assets abroad, reduction in amount charged

Transfer pricing

Transitional provisions

Unincorporated cell companies

Unremittable overseas income

Wholesale business