SCHEDULES

SCHEDULE 12Controlled foreign companies

Part 5Minor and consequential amendments

11

In section 751A of that Act (reduction in chargeable profits for certain activities of EEA business establishments), for subsection (4) substitute—

4

The Commissioners may grant the application only if—

a

they are satisfied that the specified amount does not exceed the amount (if any) equal to so much of those chargeable profits as can reasonably be regarded as representing the net economic value which—

i

arises to the appropriate body of persons (taken as a whole), and

ii

is created directly by qualifying work, and

b

they have not previously granted an application made by the UK resident company in respect of the relevant accounting period under section 751AB or 751AC.