INTM194200 - Controlled Foreign Companies: Introduction to the CFC Charge: Chargeable Profits of a CFC
A CFC바카라 사이트™s chargeable profits for an accounting period are its assumed taxable total profits (as defined at Chapter 19 in INTM239000) for that period, to the extent that the CFC바카라 사이트™s assumed total profits pass through the CFC charge gateway (see INTM194300) and have been relieved on a proportionate basis as provided for in step 2 of section 4(2) of Corporation Tax Act 2010.
The CFC바카라 사이트™s chargeable profits for that period however are subject to any adjustment for settlement income that falls to be included in the CFC바카라 사이트™s chargeable profits by virtue of TIOPA10/S371SB(4) and adjusted by TIOPA10/S371SB(7) and (8). The effect of these provisions is to include in chargeable profits, income accruing in a trust for which the CFC is a settlor or a beneficiary. Subsections (7) and (8) include measures to avoid taxing the same income twice i.e. on both the beneficiary and the settlor.