Anti-avoidance provision

Prescribed schemes

Commentary – Tax Reporter ¶173-820–Tax Reporter ¶173-855

Anti-avoidance provisions

Counteraction notices

Commentary – Tax Reporter ¶173-800–Tax Reporter ¶173-810

Chargeable gains

Companies

Commentary – Tax Reporter ¶753-200

Controlled foreign companies

Company residence

Commentary – Tax Reporter ¶770-055

Generally

Commentary – Tax Reporter ¶768-260 ; Tax Reporter ¶770-285

Loan relationships

Commentary – Tax Reporter ¶717-360
HMRC Guidance – CFM61120

Non-resident companies

Certificate of residence

Commentary – Tax Reporter ¶764-520
HMRC Guidance – INTM162020 ; INTM162160

Generally

Commentary – Tax Reporter ¶764-500

Petroleum revenue tax

Specified foreign fields

Commentary – Tax Reporter ¶799-625

Tax credits

Commentary – Tax Reporter ¶799-550

Transmedian fields

Commentary – Tax Reporter ¶799-575

Underlying tax

Accumulated losses

Commentary – Tax Reporter ¶173-600
HMRC Guidance – INTM162060

Bought in, restriction of relief

Commentary – Tax Reporter ¶173-640

Calculation

Commentary – Tax Reporter ¶173-600
HMRC Guidance – INTM162060

Control, required level

Commentary – Tax Reporter ¶173-600
HMRC Guidance – INTM162060

Controlled foreign companies, acceptable distributions policy

Commentary – Tax Reporter ¶173-610
Case Law – Bowater Paper Corporation Ltd. v. Murgatroyd (H.M. Inspector of Taxes) Bowater Paper Corporation Ltd. v. Commissioners of Inland Revenue

Deduction for dividend payment, denial of relief

Commentary – Tax Reporter ¶173-605

Disclaimer

Commentary – Tax Reporter ¶173-670

Dividend, credit in respect of

Commentary – Tax Reporter ¶173-610
Case Law – Bowater Paper Corporation Ltd. v. Murgatroyd (H.M. Inspector of Taxes) Bowater Paper Corporation Ltd. v. Commissioners of Inland Revenue

Extension of

Commentary – Tax Reporter ¶173-620

Foreign companies treated as a single entity

Commentary – Tax Reporter ¶173-635

Generally

Commentary – Tax Reporter ¶173-600
HMRC Guidance – INTM162060

Mixer cap

Commentary – Tax Reporter ¶173-620

Nature of foreign entity

Commentary – Tax Reporter ¶173-600
HMRC Guidance – INTM162060

Relevant profits

Commentary – Tax Reporter ¶173-610
Case Law – Bowater Paper Corporation Ltd. v. Murgatroyd (H.M. Inspector of Taxes) Bowater Paper Corporation Ltd. v. Commissioners of Inland Revenue

Restriction of relief, mixer cap

Commentary – Tax Reporter ¶173-615
HMRC Guidance – INTM164100

Single entity, foreign companies treated as

Commentary – Tax Reporter ¶173-635

Spared tax

Commentary – Tax Reporter ¶173-620

Split rate taxes

Commentary – Tax Reporter ¶173-600
HMRC Guidance – INTM162060

Transfer of profits between foreign companies

Commentary – Tax Reporter ¶173-630

UK tax included in

Commentary – Tax Reporter ¶173-625

Unrelieved foreign tax, dividends post-1 July 2009

Allowance for

Commentary – Tax Reporter ¶173-660

Eligible unrelieved foreign tax

Commentary – Tax Reporter ¶173-665 ; Tax Reporter ¶173-675–Tax Reporter ¶173-680

Excluded dividends

Commentary – Tax Reporter ¶173-670

Foreign permanent establishments of UK companies

Commentary – Tax Reporter ¶173-690

Generally

Commentary – Tax Reporter ¶173-650

Group surrender

Commentary – Tax Reporter ¶173-675

Onshore pooling of dividends

Commentary – Tax Reporter ¶173-670

Surplus foreign tax

Commentary – Tax Reporter ¶173-665

UK permanent establishments of non-residents

Commentary – Tax Reporter ¶173-685