INTM256060 - Controlled Foreign Companies: EEA states - deduction for net economic value against apportionment: Conditions for application to treat a controlled foreign company鈥檚 profits as reduced
A UK resident company that has a 鈥渞elevant interest鈥� (as defined in ICTA88/S752A) in a controlled foreign company may make an application under the new rules if the following conditions are satisfied in relation to an accounting period of the controlled foreign company:
- none of the exemptions provided for in ICTA88/S748 applies (and so the controlled foreign company鈥檚 chargeable profits and creditable tax fall to be apportioned under ICTA88/S747(3)); and
- throughout the period the controlled foreign company has a business establishment in, and individuals working for it in, another EEA State (see INTM256070).