SCHEDULES

SCHEDULE 20Controlled foreign companies and foreign permanent establishments

PART 3Other amendments

FA 2000

20(1)Paragraph 57 is amended as follows.

(2)In sub-paragraph (1)(b) for the words from “controlled” to the end substitute “CFC apportioned to the company at step 3 in section 371BC(1) of the Taxation (International and Other Provisions) Act 2010.”

(3)For sub-paragraph (4) substitute—

(4)For the purposes of sub-paragraph (1)(b)—

(a)“tonnage profits” means so much of the CFC’s chargeable profits for its accounting period in question as, applying the corporation tax assumptions, are calculated in accordance with paragraph 4 of this Schedule; and

(b)so much of those chargeable profits as are tonnage profits shall be treated as apportioned at step 3 in section 371BC(1) of the Taxation (International and Other Provisions) Act 2010 in the same proportions as those profits (taken generally) are apportioned.

(4A)In sub-paragraphs (1)(b) and (4) terms defined in Part 9A of the Taxation (International and Other Provisions) Act 2010 have the same meaning as in that Part.