F1PART 9AControlled foreign companies
Chapter 17Apportionment of a CFC's chargeable profits and creditable tax
Introduction
371QBProvision about interpretation
1
This section applies for the purposes of this Chapter.
2
Section 371OB applies as it applies for the purposes of Chapter 15.
3
“Ordinary shares”, in relation to any company, means shares of a single class, however described, which is the only class of share issued by the company.
4
For the purposes of subsection (3)—
a
“share” includes a fraction of a share, and
b
shares issued by a company which are paid up to different amounts are not to be taken to be of a single class.
5
A person (“P”) holds ordinary shares in the CFC “indirectly” if P directly holds ordinary shares in a company which is share-linked to the CFC.
6
A company is “share-linked” to the CFC if it has an interest in the CFC only by virtue of it holding directly—
a
ordinary shares in the CFC, or
b
ordinary shares in another company which is share-linked to the CFC (whether by virtue of paragraph (a) or this paragraph),
and “share-linked company” means a company which is share-linked to the CFC.
Pt. 9A inserted (17.7.2012) by Finance Act 2012 (c. 14), Sch. 20 para. 1 (with ss. 56-58)