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

Definitions

Section 371VA provides a glossary of key terms used throughout Part 9A of the Act, which deals with the controlled foreign companies (CFC) regime.

• The section defines core CFC concepts such as "CFC", "the CFC charge", "chargeable company", "chargeable profits", "control", and "accounting period", each of which has its detailed meaning set out in other specific sections of Part 9A.
• It defines financial and profit-related terms including "assumed taxable total profits", "assumed total profits", "accounting profits", "trading profits", "trading income", "non-trading income", "trading finance profits", "non-trading finance profits", and "property business profits".
• It provides definitions for business and commercial terms such as "banking business", "insurance business", "intellectual property", "contract of insurance", "relevant finance lease", "arrangement", and "tax advantage".
• It also defines structural and procedural terms including "company tax return", "the HMRC Commissioners", "UK connected capital contribution", "UK permanent establishment", "interest" (in a company), "relevant interest", "creditable tax", "the local tax amount", and "the corporation tax assumptions".