Acceptable distribution policy test (pre-1 July 2009

Appropriate portion of profits

Attribution of dividends to accounting periods and to profits

Available profits, pre-28 November 1995

Chargeable profits, meaning

Conditions

Disqualification of dividends paid out of specified profits

Dividends paid to UK companies constituting trading income part of tax avoidance scheme

Flowchart

Generally

Matching dividends paid with profits, distribution condition

Non-trading companies pre-28 November 1995

Routing of dividends from another UK subsidiary, test not satisfied

Transitional provisions

UK residents with indirect interests, dividend chains

Underlying tax on dividends

Accounting period

Appeals to special commissioners

Apportionment

Accounting period, meaning

Charge to tax

Direct and indirect interests

Generally

Life assurance companies

Method of

Persons who have an interest

Relevant interests

Assessment and recovery of tax

Calculation of apportioned profits

Claims for relief, assumptions

Company assumed not to be close

Company assumed not to be in group

Company reconstructions

Creditable tax

Generally

Losses previously incurred

Residence, assumptions as to

Unremittable overseas income

Charge to tax

Clearance procedures

Generally

Non-trading

Currency

Capital allowances, computation

Chargeable profits to be computed and expressed in

Foreign exchange gains and losses

Designer rate tax regimes

EU law

Apportionment

Case law

Exempt activities test

Freedom of establishment

Generally

Genuine as opposed to wholly artificial arrangements, meaning

Genuine economic activities, HMRC's views

Motive test

Relationship with UK legislation

Excluded countries list

Exempt activities test

Advance clearance, information required

Banking and similar business, special provisions

Business establishment

Effective managements of business affairs

Flowchart

Generally

Holding companies

Insurance, special provisions

Nature of business

Residence

Exempt period test

Beginning of exempt period

Ending o0f exempt period

Generally

Exemptions

Generally

Territorial exclusions

Foreign exchange gains and losses

Future entitlement to an interest

Groups of companies finance expenses, reduction in chargeable profits

Holding companies

Exempt activities test

Generally

Motive test

Not qualifying holding companies

Qualifying holding companies

Types of holding company which satisfy exempt activities test

Information, HMRC's power

Insurance companies

Chargeable profits

General insurance business

Legislation, summary

Limited UK connection test

Business activities test

Business establishment test

Generally

Intellectual property exploitation

Reduction in chargeable profits where there is relevant failure

Trading companies

UK connection test

Meaning

Company residence

Control

Generally

Lower level of taxation

Method of apportionment

Appeals

Fiduciary capacity

Indirect interests

Interest not held throughout accounting period

Loan creditors

Nominees or bare trustees

Winding up

Motive test

Achieving a diversion of profits

Achieving a reduction in UK tax

EU law

Excluded countries list

Generally

HMRC guidance

Holding companies

Main purpose

Transaction, meaning

Non-trading companies clearance procedures

Notice of direction/declaration

Appeals against

Generally

Procedure in appeals

Revision of notice by inspector

Persons having an interest

Postponement of tax

Public quotation test

Reliefs available to UK company charged

Advance corporation tax

Dividends from the controlled foreign company

Gains on disposal of shares

Generally

Trading losses and group relief

Residence

Returns

Self-assessment

Determinations

Generally

Postponement of tax

Recovery of tax

Returns

Right of appeal

Small chargeable profits test

Small relevant profits test

Trading currency

UK tax charge

Unremittable overseas income