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

Overview of Chapter

Section 371SA introduces the chapter that defines key profit concepts used when calculating the UK tax charge on controlled foreign companies (CFCs).

• This chapter explains three important terms that are used throughout the CFC rules in Part 9A of the Act.
• "Assumed taxable total profits" and "assumed total profits" represent the profits a CFC would be treated as having if it were a UK-resident company subject to corporation tax.
• "The corporation tax assumptions" are the set of assumptions applied to work out those profit figures, essentially treating the CFC as if it were within the UK tax system.
• These concepts are central to determining how much, if any, of a CFC's profits may give rise to a UK tax charge on its controlling UK companies.