INTM233500 - Controlled Foreign Companies: Apportionment of a CFC바카라 사이트™s Chargeable Profits and Creditable Tax: Variable Shareholdings
TIOPA/S371QF applies to determine the percentage of issued ordinary shares that R바카라 사이트™s relevant interest represents where that percentage holding varies during the accounting period. The relevant interest is the sum of the relevant percentages for each holding period. For example, if during the accounting period the amount of R바카라 사이트™s relevant interest changes three times, then the overall relevant interest for the accounting period is found by adding together the relevant percentage calculated for each of the three holding periods.
This is given by the formula (P x H)/A where:
P is the percentage of ordinary shares held (based on the formula P x S in INTM233400) for each period in which the shareholding remained the same during the CFC바카라 사이트™s accounting period;
H is the number of days for which the shareholding remained the same - the 바카라 사이트˜holding period바카라 사이트™;
A is the number of days in the accounting period of the CFC.
Example - variable shareholdings
Company A holds 60% of the CFC바카라 사이트™s issued ordinary shares as a relevant interest during the first 100 days of the accounting period and 80% during the remaining 265 days of the accounting period.
The percentage of the CFC바카라 사이트™s issued share capital that A바카라 사이트™s relevant interest represents in the accounting period is the sum of the relevant percentages for the two holding periods:
Holding period 1: relevant percentage is 60% x 100/365 = 16.4%,
Holding period 2: relevant percentage is 80% x 265/365 = 58.1%.
Thus the percentage of the CFC바카라 사이트™s issued share capital that A바카라 사이트™s relevant interest represents in the accounting period is 16.4% plus 58.1%, which is 74.5%.