Finance Act 2012 (c. 14)

SCHEDULES

SCHEDULE 20 U.K. Controlled foreign companies and foreign permanent establishments

PART 3 U.K. Other amendments

CTA 2010 U.K.

39 (1) Section 938M (group mismatch schemes: controlled foreign companies) is amended as follows. U.K.

(2) In subsection (1) for the words from the beginning to “company” substitute “ Section 371SL(1) of TIOPA 2010 (assumption that a CFC ”.

(3) In subsection (2)—

(a) for “chargeable profits” substitute “ assumed taxable total profits ”, and

(b) for “Chapter 4 of Part 17 of ICTA” substitute “ Part 9A of TIOPA 2010 ”.