78 Controlled foreign companies and treaty non-resident companies

International matters

78  Controlled foreign companies and treaty non-resident companies

(1)     Section 90 of FA 2002 (controlled foreign companies and treaty non-resident companies) is amended as follows.

(2)     In subsection (2) (application of subsection (1), which inserted section 747(1B) of ICTA (disregard of section 249 of FA 1994 for most purposes of Chapter 4 of Part 17 of ICTA (controlled foreign companies))), for paragraph (b) (exclusion for companies which were non-resident immediately before 1st April 2002) substitute—

“(b)     does not apply to a company (“the non-resident company”) that—

(i)     by virtue of section 249 of the Finance Act 1994 was treated as resident outside the United Kingdom, and not resident in the

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