SCHEDULES
SCHEDULE 20Controlled foreign companies and foreign permanent establishments
PART 3Other amendments
45TIOPA 2010
After section 314 insert—
314AThe financing income amounts of a chargeable company under Part 9A
1
This section applies if—
a
b
c
the CFC’s accounting period in relation to which the sum is charged ends in the period of account of the worldwide group, and
2
An amount equal to P% of the relevant finance profits is to be taken to be a financing income amount of the company for the period of account of the worldwide group.
3
4
In subsection (1)(d) the reference to amounts which fall within Chapter 5 or 6 of Part 9A or which are qualifying loan relationship profits is limited to amounts—
a
which so fall or which are such profits by virtue of section 297 or 299 of CTA 2009 (but not, in the case of section 299, as applied by section 574 of that Act), and
b
which are not excluded credits (as defined in section 314(3) above).