Part 3

Income tax, corporation tax and capital gains tax
Chapter 2

Other provisions

International matters

Controlled foreign companies and treaty non-resident companies
90
1
In section 747 of the Taxes Act 1988 (imputation of chargeable profits and creditable tax of controlled foreign companies), after subsection (1A) insert—
1B
In determining, for the purposes of any provision of this Chapter except subsection (1)(a) above, whether a company is a person resident in the United Kingdom, section 249 of the Finance Act 1994 (under which a company is treated as non-resident if it is so treated for double taxation relief purposes) shall be disregarded.
.
2
Subsection (1)—
a
shall be deemed to have come into force on 1st April 2002, and
b
does not apply to a company that—
i
by virtue of section 249 of the Finance Act 1994 (c. 9) was treated as resident outside the United Kingdom, and not resident in the United Kingdom, immediately before that date, and
ii
has not subsequently ceased to be so treated.