SCHEDULES
SCHEDULE 16Controlled foreign companies
Part 1Abolition of acceptable distribution policy exemption
Periods straddling 1 July 2009
7
1
Where a controlled foreign company has an accounting period (“the straddling accounting period”) that—
a
begins before 1 July 2009, and
b
ends on or after that date,
the straddling accounting period is to be treated as split.
2
Where this paragraph provides that the straddling accounting period is to be treated as “split”—
a
that part of the straddling accounting period that falls before 1 July 2009 and that part of the straddling accounting period that falls on or after that date are to be treated for the purposes of Chapter 4 of Part 17, and Part 18, of ICTAF1and Part 2 of TIOPA 2010 as separate accounting periods, and
b
the company's chargeable profits for the straddling accounting period, and its creditable tax (if any) for that period, are to be apportioned to the two separate accounting periods on a just and reasonable basis.