835X Relief for certain distributions

Summary

This section provides that if a distribution is subsequently made out of chargeable income (i.e. previously undistributed income that has been subject to a CFC charge), then an amount equal to the tax on the charge shall be allowed as a credit against any tax arising in respect of the distribution.

Details

(1) If a distribution is subsequently made out of chargeable income (i.e. previously undistributed income that has been subject to a CFC charge), then an amount equal to the tax on the charge shall be allowed as a credit against any tax arising in respect of the distribution.

(2) Where a distribution is made by a CFC partly out of chargeable income and partly out of other income then the distribution is treated as two separate distributions and any available credit is apportioned respectively.

Relevant Date: Finance Act 2019