Part 2Charge to corporation tax: basic provisions
F1CHAPTER 3AUK RESIDENT COMPANIES: PROFITS OF FOREIGN PERMANENT ESTABLISHMENTS
Anti-diversion rule
F218ICThe low profit margin exemption
(1)
Chapter 13 of Part 9A of TIOPA 2010 (controlled foreign companies: the low profit margin exemption) applies for the purposes of section 18G(1)(c) with the following modifications.
(2)
In section 371MB—
(a)
subsection (2) is to be omitted, and
(b)
references to the CFC's accounting profits for an accounting period are to be read as references to the adjusted relevant profits amount determined before any deduction for interest.