SCHEDULES

SCHEDULE 16Controlled foreign companies

Part 1Abolition of acceptable distribution policy exemption

Consequential amendments

2

1

ICTA is amended as follows.

2

Omit section 754A (returns where it is not established whether acceptable distribution policy applies).

3

In section 801 (dividends paid between related companies: relief for UK and third country taxes), omit subsections (2A)(aa), (2B), (6) and (7).

4

Omit section 801C (double taxation relief: separate streaming of dividend so far as representing an ADP dividend of a CFC).

5

In section 803A (foreign taxation of group as single entity), omit subsection (1A).

6

In Schedule 24 (assumptions for calculating chargeable profits, creditable tax and corresponding UK tax of foreign companies), omit—

a

in paragraph 1(3A), paragraph (b)(ii) (and the “and” before it) and the words “or which is an ADP exempt period” (in both places),

b

paragraph 1(6),

c

paragraph (b) of paragraph 2(1) (and the “or” before it),

d

paragraph (b) of paragraph 4(1A) (and the “or” before it),

e

paragraph 4(3A),

f

in paragraph 9(1)(c), “, and is not to be assumed by virtue of paragraph 2(1)(b) above to have been resident,”, and

g

paragraph (b) of paragraph 10(1) (and the “or” before it).