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HMRC internal manual

International Manual

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Controlled Foreign Companies: Creditable Tax of a CFC: contents

Where the charging provisions at TIOPA10/ S371BC apply to a CFC, Step 2 of TIOPA10/S371BC(1) states that, in establishing the CFC charge, it is necessary to determine the CFC’s creditable tax for the accounting period in accordance with Chapter 16. The amount of creditable tax calculated under Chapter 16 is then apportioned among the relevant persons (in accordance with Chapter 17) for the purposes of step 3 of TIOPA10/S371BC(1).