SCHEDULES
SCHEDULE 25F1Cases where section 747(3) does not apply
PART I ACCEPTABLE DISTRIBUTION POLICY
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F4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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F4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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F4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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F4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
F24A
Subject to sub-paragraph (5) below, for the purposes of this Part of this Schedule, the net chargeable profits of a controlled foreign company for any accounting period are—
a
its chargeable profits for that period, less
b
the amount (if any) which, if F6an apportionment under section 747(3) fell to be made in respect of the period, would be the company’s unrestricted creditable tax for that period;
and for the purposes of this sub-paragraph “unrestricted creditable tax” in relation to a company’s accounting period means the amount which would be its creditable tax for that period if the reference in section 751(6)(a) to Part XVIII did not include section 797.
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In any case where—
a
a controlled foreign company pays a dividend for any period out of specified profits, and
b
those profits represent dividends received by the company, directly or indirectly, from another controlled foreign company,
so much of those specified profits as is equal to the dividend referred to in paragraph (a) above shall be left out of account in determining, for the purposes of this Part of this Schedule,F5. . . F3the chargeable profits of the controlled foreign company referred to in that paragraph for any accounting period.
Sch. 25 heading substituted (with effect in accordance with Sch. 17 para. 37 of the amending Act) by Finance Act 1998 (c. 36), Sch. 17 para. 25; S.I. 1998/3173, art. 2