Anti-avoidance provision

Prescribed schemes

Anti-avoidance provisions

Counteraction notices

Chargeable gains

Companies

Controlled foreign companies

Company residence

Generally

Loan relationships

Non-resident companies

Certificate of residence

Generally

Petroleum revenue tax

Specified foreign fields

Tax credits

Transmedian fields

Underlying tax

Accumulated losses

Bought in, restriction of relief

Calculation

Control, required level

Controlled foreign companies, acceptable distributions policy

Deduction for dividend payment, denial of relief

Disclaimer

Dividend, credit in respect of

Extension of

Foreign companies treated as a single entity

Generally

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

Generally

Group surrender

Onshore pooling of dividends

Surplus foreign tax

UK permanent establishments of non-residents