SCHEDULES

SCHEDULE 16U.K.Controlled foreign companies

Part 1U.K.Abolition of acceptable distribution policy exemption

Consequential amendmentsU.K.

2(1)ICTA is amended as follows.U.K.

(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).