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HMRC internal manual

International Manual

HM Revenue & Customs
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Controlled Foreign Companies: EEA states - deduction for net economic value against apportionment: Conditions for application to treat a controlled foreign company’s profits as reduced

A UK resident company that has a “relevant interest” (as defined in ICTA88/S752A) in a controlled foreign company may make an application under the new rules if the following conditions are satisfied in relation to an accounting period of the controlled foreign company:

  1. none of the exemptions provided for in ICTA88/S748 applies (and so the controlled foreign company’s chargeable profits and creditable tax fall to be apportioned under ICTA88/S747(3)); and
  2. throughout the period the controlled foreign company has a business establishment in, and individuals working for it in, another EEA State (see INTM256070).