Part 2Charge to corporation tax: basic provisions

F1CHAPTER 3AUK RESIDENT COMPANIES: PROFITS OF FOREIGN PERMANENT ESTABLISHMENTS

Anti-diversion rule

F218HBModification of Chapter 4 of Part 9A of TIOPA 2010

(1)

Chapter 4 of Part 9A of TIOPA 2010 (the CFC charge gateway: profits attributable to UK activities) applies for the purposes of section 18H(2) with the following modifications.

(2)

The modifications are—

(a)

section 371DA(3)(g)(i) is to be omitted, and

(b)

in section 371DH(4), after “the accounting period”, in the second place it occurs, there is to be inserted “ or the United Kingdom ”.

(3)

Section 371VF(3) of TIOPA 2010 (definition of “related” person) is to be applied as relevant with the omission of paragraphs (b) and (c).