Part 1 Abolition of Acceptable Distribution Policy Exemption

SCHEDULE 16 Controlled Foreign Companies

Section 36

Part 1 Abolition of Acceptable Distribution Policy Exemption

Abolition of acceptable distribution policy exemption

1

(1)     ICTA is amended as follows.

(2)     In section 748(1) (cases where apportionment under section 747(3) does not apply), omit paragraph (a) (including the “or†at the end).

(3)     In Schedule 25 (supplementary provision in relation to cases where apportionment under section 747(3) does not apply), omit Part 1 (acceptable distribution policy).

Consequential amendments

2

(1)     ICTA is amended as follows.

(2)     Omit section 754A (returns where it is not established whether acceptable distribution policy applies).

(3)     In section 801 (dividends paid between related companies: relief for UK and third country taxes), omit subsections (2A)(aa), (2B), (6) and (7).

(4)     Omit section 801C (double taxation relief: separate streaming of dividend so far as representing an ADP dividend of a CFC).

(5)     In section 803A (foreign taxation of group as single entity), omit subsection (1A).

(6)     In Schedule 24 (assumptions for calculating chargeable profits, creditable tax and corresponding UK tax of foreign companies), omit—

(a)

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