Part 3 Reduction in Chargeable Profits for Certain Financing Income

Part 3 Reduction in Chargeable Profits for Certain Financing Income

Reduction in chargeable profits for certain financing income

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ICTA is amended as follows.

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After section 751A insert—

“751AA Reduction in chargeable profits for certain financing income

(1)     This section applies if—

(a)     an apportionment under section 747(3) falls to be made as regards an accounting period (“the relevant accounting periodâ€) of a controlled foreign company,

(b)     the chargeable profits of the controlled foreign company for the relevant accounting period would, apart from this section, include an amount of income in respect of a payment made by another company (“the payerâ€),

(c)     the amount that the payer brings into account for the purposes of corporation

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