Anti-avoidance provision

Prescribed schemes

Anti-avoidance provisions

Counteraction notices

Chargeable gains


Controlled foreign companies

Company residence


Non-resident companies

Certificate of residence


Petroleum revenue tax

Specified foreign fields

Tax credits

Transmedian fields

Underlying tax

Accumulated losses

Bought in, restriction of relief


Control, required level

Controlled foreign companies, acceptable distributions policy

Deduction for dividend payment, denial of relief


Dividend, credit in respect of

Extension of

Foreign companies treated as a single entity


Mixer cap

Nature of foreign entity

Relevant profits

Restriction of relief, mixer cap

Single entity, foreign companies treated as

Spared tax

Split rate taxes

Transfer of profits between foreign companies

UK tax included in

Unrelieved foreign tax, dividends post-1 July 2009

Allowance for

Eligible unrelieved foreign tax

Excluded dividends

Foreign permanent establishments of UK companies


Group surrender

Onshore pooling of dividends

Surplus foreign tax

UK permanent establishments of non-residents