Link Report

“connected” shall be construed in accordance with section 10;

but does not include an arrangement referred to in section 826;

“corresponding chargeable profits in the State” means those profits or gains of a controlled foreign company which would be the controlled foreign company’’s profits or gains for corporation tax or capital gains tax purposes for an accounting period if the assumptions specified in section 835O were to apply to that company;

“corresponding corporation tax in the State” means the amount of corporation tax and capital gains tax which would be chargeable in the State in respect of the controlled foreign company’’s corresponding chargeable profits in the State for the accounting period in accordance with section 835P if the assumptions specified in section 835O were to apply to the company;

“non-trading income” means the income of a controlled foreign company which would be included in the controlled foreign company’’s corresponding chargeable profits in the State if the assumptions specified in section 835O were to apply to the company, other than income which would be chargeable to tax under Case I or II of Schedule D, were those assumptions to apply;

“corresponding corporation tax in the State” means the amount of corporation tax and capital gains tax which would be chargeable in the State in respect of the controlled foreign company’’s corresponding chargeable profits in the State for the accounting period in accordance with section 835P if the assumptions specified in section 835O were to apply to the company;

“undistributed income” shall be construed in accordance with section 835Q.

“controlled foreign company charge” means a charge made under section 835R(2);

“creditable tax” shall be construed in accordance with section 835S;