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 19Assumed taxable total profits, assumed total profits and the corporation tax assumptions

“The corporation tax assumptions”

371SFClaims and elections

1

In relation to any relief under the Corporation Tax Acts which is dependent upon the making of a claim or election, assume the CFC—

a

to have made that claim or election which would give the maximum amount of relief, and

b

to have made that claim or election within any applicable time limit.

2

Subsection (1) does not cover (so far as it would otherwise do so) a claim or election under—

a

section 18A of CTA 2009 (exemption for profits or losses of foreign permanent establishments),

b

section 1275 of CTA 2009 (relief for unremittable income),

c

section 9A of CTA 2010 (designated currency of a UK resident investment company), or

d

regulations made under paragraph 16 of Schedule 8 to FA 2006 (election for lease to be treated as long funding lease).

3

Subsection (1) is also subject to section 371SK(5).