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

UK residence etc

Section 371SD establishes the key fiction underlying the CFC regime: that a controlled foreign company is treated as if it were UK resident and within the charge to corporation tax, so that its profits can be calculated on a UK tax basis.

Access full legislation.And much more.

By becoming a member, your team gets full access to Tax World research tools and source-backed tax resources.