Taxation (International and Other Provisions) Act 2010 section 371QA

Application of Chapter

Section 371QA introduces the rules for dividing up a controlled foreign company's chargeable profits and creditable tax among the relevant UK corporate shareholders.

• This chapter sets out how a CFC's chargeable profits are apportioned among relevant persons (broadly, UK corporate shareholders with at least a 25% interest).
• It also covers how creditable tax (foreign tax that can be credited against the CFC charge) is divided among those same persons.
• The apportionment applies to each accounting period of the CFC.
• This apportionment is required as step 3 in the process of calculating and imposing the CFC charge under section 371BC(1).