INTM256020 - Controlled Foreign Companies: EEA states - deduction for net economic value against apportionment: Overview of the new rules
The controlled foreign companies바카라 사이트� rules provide a number of general exemptions. Where none of these are available these rules provide an additional mechanism for excluding profits from apportionment to a UK company.
The rules can apply in relation to any controlled foreign company that has individuals working for it in a business establishment in another EEA state. If the controlled foreign company바카라 사이트檚 profits would otherwise have to be apportioned, the UK owners of the controlled foreign company may apply to HMRC for the company바카라 사이트檚 apportionable profits to be treated as reduced by an amount (바카라 사이트渢he specified amount바카라 사이트�) representing the 바카라 사이트渘et economic value바카라 사이트� arising to the group that is created directly by the work of those individuals.
HMRC must grant the application providing the company바카라 사이트檚 application demonstrates that the specified amount satisfies the criteria set out in the new rules. Once the UK Company바카라 사이트檚 application has been granted, the controlled foreign company바카라 사이트檚 chargeable profits and creditable tax are treated as reduced for the purposes of determining the UK company바카라 사이트檚 controlled foreign companies바카라 사이트� charge.
The rules also provide a new 바카라 사이트渆ffectively managed바카라 사이트� condition in ICTA88/SCH25/PARA8 for the purposes of applying the Exempt Activities exemption to a controlled foreign company resident in another EEA state.