| INTM208010 |
Introduction to the motive test |
| INTM208020 |
The conditions of the motive test |
| INTM208030 |
The transaction leg of the motive test: transactions reducing United Kingdom tax |
| INTM208040 |
The transaction leg of the motive test: statutory definition |
| INTM208050 |
The transaction leg of the motive test: are the results of the transaction(s) reflected in the controlled foreign company's profits for an accounting period? |
| INTM208060 |
The transaction leg of the motive test: reduction in United Kingdom tax? |
| INTM208070 |
The transaction leg of the motive test: reduction in United Kingdom tax more than minimal? |
| INTM208080 |
The transaction leg of the motive test: motive element |
| INTM208090 |
The diversion of profits leg of the motive test |
| INTM208100 |
The diversion of profits leg of the motive test: statutory definition |
| INTM208110 |
The diversion of profits leg of the motive test: are there receipts reflected in the controlled foreign company's profits for an accounting period? |
| INTM208120 |
The diversion of profits leg of the motive test: in the absence of the controlled foreign company (and any 'related company'), would it be reasonable to suppose that the whole or a substantial part of those receipts would have been received by a United Kingdom person? |
| INTM208130 |
The diversion of profits leg of the motive test: related company |
| INTM208140 |
The diversion of profits leg of the motive test: United Kingdom company |
| INTM208150 |
The diversion of profits leg of the motive test: would the United Kingdom person have paid more, or been entitled to less relief from, United Kingdom tax? |
| INTM208160 |
The diversion of profits leg of the motive test: motive element |
| INTM208170 |
Application of motive test: overview |
| INTM208180 |
Application of motive test: 'marginal and isolated failure' of exempt activities and excluded countries exemptions |
| INTM208190 |
Application of motive test: newly-established overseas business |
| INTM208200 |
Application of motive test: incorporation of foreign branch |
| INTM208210 |
Application of motive test: United Kingdom takeover of overseas group - 'period of grace' |
| INTM208220 |
Application of motive test: holding companies - background |
| INTM208230 |
Application of motive test: holding companies - 21 March 2000 example |
| INTM208240 |
Application of motive test: holding companies - avoidance of United Kingdom or foreign tax |
| INTM208250 |
Application of motive test: holding companies - conduit companies |
| INTM208260 |
Application of motive test: Venture Capital Limited Partnerships |
| INTM208270 |
Application of motive test: loan relationships legislation |
| INTM208280 |
Application of motive test: examples - 'marginal and isolated failure' of exempt activities and excluded countries exemptions |
| INTM208290 |
Application of motive test: examples - United Kingdom takeover of overseas group |
| INTM208300 |
Application of motive test: examples - locally based traders failing the exempt activities test |
| INTM208310 |
Application of motive test: examples - intra-group service providers failing the exempt activities test |
| INTM208320 |
Application of motive test: examples - controlled foreign company’s profits effectively subject to tax in the United Kingdom |
| INTM208330 |
Application of motive test: examples - captive insurance companies |
| INTM208340 |
Application of motive test: examples - 'money boxes' |
| INTM208350 |
Application of motive test: examples - holding companies |
