Double taxation relief (companies)
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