Controlled foreign companies (pre-1 January 2013)
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
