SCHEDULES

SCHEDULE 15Controlled foreign companies

Imputation of chargeable profits and creditable tax of controlled foreign companies

1

1

Section 747 of ICTA (imputation of chargeable profits and creditable tax of controlled foreign companies) is amended as follows.

2

After subsection (3) insert—

3A

In the case of an apportionment to a company resident in the United Kingdom which has made an application under section 751A which has been granted, subsection (3) above has effect subject to that section.

3

After subsection (5) insert—

5A

Where the resident company has made an application under section 751A which has been granted, it shall be assumed for the purposes of subsection (5) above that—

a

each of the persons who are connected or associated with the resident company has made an application under that section to the same effect, and

b

all the applications have been granted.