Income Tax Act 2007

725 Reduction in amount charged where controlled foreign company involved

(1) This section applies if—

(a) an amount of the chargeable profits for an accounting period of a company (“the controlled foreign company”) is apportioned to one or more UK resident companies under section 747(3) of ICTA (imputation of chargeable profits and creditable tax of controlled foreign companies),

(b) as a result of section 747(4) of that Act those companies are chargeable in respect of the amount (“the chargeable amount”) of the chargeable profits so apportioned to them, and

(c) apart from this section, the amount of income treated as arising to an individual under section 721 for a tax year would be or include a sum forming part of the controlled foreign company’s chargeable profits for that accounting period.

(2) The amount of income so treated is reduced by—

where—

• S is the sum forming part of the controlled foreign company’s chargeable profits for that accounting period,

• CA is the chargeable amount, and

• CP is the controlled foreign company’s chargeable profits for that accounting period.

(3) The following provisions of ICTA apply for the purposes of this section as they apply for the purposes of Chapter 4 of Part 17 of that Act—

• section 747(6) (interpretation, in relation to a non-UK resident company, of references to chargeable profits for an accounting period and profits), and

• section 751(1) to (5A) (accounting periods).