[371FA The basic rule]

[Chapter 6
The CFC Charge Gateway: Trading Finance Profits]

[371FA  The basic rule]

[(1)     Take the following steps to determine the CFC's profits falling within this Chapter for the purposes of step 2 in section 371BB(1) (the CFC charge gateway).

This is subject to regulations under section 371FD or 371FE.

Step 1

Determine if, during the accounting period, the CFC's free capital exceeds what it is reasonable to suppose its free capital would be were it a company which is not the 51% subsidiary of any other company.

If there is excess free capital, “the step 1 amount” is—

(a)     the excess free capital, or

(b)     if less, the CFC's free capital so far as deriving (directly or indirectly) from UK connected capital contributions.

Step 2

This step

Powered by Lexis+®

Popular documents