INTM211010 - Reliefs against Controlled Foreign Companies' tax

Relevant allowances

ICTA88/S754(5) and ICTA88/SCH26/PARA1(3)

A self assessment under Chapter IV is on an amount charged at the 'appropriate rate' (see INTM210010) on the chargeable profits apportioned to a United Kingdom company in respect of its interest in a controlled foreign company, less any creditable tax included in the apportionment. ICTA88/S754(5) makes it clear that no reliefs other than those provided in ICTA88/SCH26 are available to the United Kingdom company to set against the net Chapter IV charge.

The reliefs which qualify for set-off, subject to the conditions of ICTA88/SCH26, are described as 'relevant allowances'. The relevant allowances are as follows:

1. Losses to which ICTA88/S393A(1) applies.
2. Charges on income to which ICTA88/S338(1) applies.
3. Expenses of management to which ICTA88/SS75(1) applies.
4. So much of any allowance to which CAA90/S145 applies as falls within subsection (3).
5. Amounts available to the company by way of group relief.
6. Any non-trading deficit on its loan relationships.