INTM215290 - Controlled Foreign Companies: before CTSA

Apportionment: overview

The Board may direct that Chapter IV is to apply - see INTM215090. If so, the chargeable profits and creditable tax for the accounting period of the controlled foreign company are computed and apportioned among the persons who have an interest in the company at any time during the accounting period. This applies whether the persons are resident in the United Kingdom or not.

The Inspector then makes assessments for the apportioned profits, unless they are below the limit in INTM210030. The Inspector assesses the companies resident in the United Kingdom to which those profits are apportioned.

For periods prior to the introduction of self assessment for companies, the basis on which chargeable profits etc are apportioned is a matter for the Board. The Inspector should, however, know about the possible ways to do this. This is relevant to any general review of a controlled foreign company's affairs. The Inspector may also need to comment on this in a report under INTM215200.

See INTM215300 and following pages for matters relating to apportionment which are specific to periods before the introduction of self assessment for companies. See INTM209000 and following pages for general guidance on the computation of chargeable profits and creditable tax and INTM210000 and following pages for general guidance on the apportionment of chargeable profits and creditable tax.