Part 3 Temporary Exemption Following Reorganisation etc

Part 3 Temporary Exemption Following Reorganisation etc

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(1)     Section 748 of ICTA (cases where section 747(3) does not apply) is amended as follows.

(2)     After subsection (1)(e) insert

“; or

(f)     the accounting period ends during an exempt period in relation to the company (see Part 3A of Schedule 25).â€

(3)     In subsection (3) for “(e)†substitute “(f)â€.

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After section 751AB of that Act (inserted by paragraph 2 of this Schedule) insert—

“751AC Reduction in chargeable profits following an exempt period

(1)     This section applies if—

(a)     an exempt period in relation to a controlled foreign company ends in accordance with paragraph 15F(2) of Schedule 25 (time exempt period ends if there is an early termination event), other than by reason of an early termination event within paragraph 15F(3)(b),

(b)     an accounting period (“the relevant accounting periodâ€) of the company ends after that exempt period but before the time the exempt period would have ended had paragraph 15F(2) of that Schedule not applied,

(c)     an apportionment under section 747(3) would fall to be made as regards the relevant accounting period, and

(d)     a company resident in the United Kingdom (“the UK resident companyâ€) has a relevant

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