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  1. Home
HMRC internal manual

International Manual

From:
HM Revenue & Customs
Published
9 April 2016
Updated:
16 May 2025 - See all updates
  1. Back to contents
  2. INTM190000
  3. INTM254000

INTM254100 - Controlled Foreign Companies: contents

This guidance applies for accounting period before 1 January 2013 and refers to the legislation at Chapter IV Part XVII of the Income and Corporation Taxes Acts 1988, under the old Controlled Foreign Companies (CFC) rules.

The current rules for CFCs are contained in Part 9A, Taxation (International and Other Provisions) Act 2010. This legislation is effective for accounting periods of CFCs beginning on or after 1 January 2013. The new guidance can be found at INTM190000 onwards.

  1. INTM254150
    legislation - introduction and outline: contents
  2. INTM254350
      definitions: contents
  3. INTM254450
      exemptions - excluded countries : contents
  4. INTM254600
      exemptions - Acceptable Distribution Policy ('ADP'): contents
  5. INTM254800
      exemptions - Exempt Activities Test ('EAT'): contents
  6. INTM255100
      exemptions - de minimis
  7. INTM255150
      the motive test: contents
  8. INTM255600
    computation of chargeable profits and creditable tax: contents
  9. INTM255850
    apportionment of chargeable profits and creditable tax: contents
  10. INTM256000
    EEA states - deduction for net economic value against apportionment: Contents
  11. INTM256100
    Reliefs against Controlled Foreign Companies' Tax: contents
  12. INTM256350
    United Kingdom companies carrying on life assurance business: contents
  13. INTM256450
      Controlled Foreign Companies carrying on general insurance business: contents
  14. INTM256600
      How the CT regime works for Controlled Foreign Companies: contents
  15. INTM256800
    reviews

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