F1PART 9AControlled foreign companies

Annotations:
Amendments (Textual)
F1

Pt. 9A inserted (17.7.2012) by Finance Act 2012 (c. 14), Sch. 20 para. 1 (with ss. 56-58)

Chapter 13The low profit margin exemption

371MCAnti-avoidance

The low profit margin exemption does not apply for a CFC's accounting period (“the relevant accounting period”) if—

a

an arrangement is entered into at any time,

b

in consequence of the arrangement, the low profit margin exemption would (apart from this section) apply for the relevant accounting period, and

c

the main purpose, or one of the main purposes, of the arrangement is to secure that the low profit margin exemption applies—

i

for the relevant accounting period, or

ii

for that period and one or more other accounting periods of the CFC.