188体育

Alphabetic index of terms defined in Part 9A

鈥淎ccounting period鈥�, in relation to a CFC, is defined at INTM248150

鈥淎ccounting profits鈥�, in relation to a CFC, is defined at INTM248200

鈥淎rrangement鈥� is used in targeted anti-avoidance rules and includes:

• any agreement, scheme, transaction or understanding (whether or not legally enforceable), and
• a series of arrangements or a part of an arrangement.

The definition of 鈥渁rrangement鈥� is wide and will cover arrangements that arise from a legal agreement between parties through to arrangements that rely only on a verbal understanding. The second bullet point means that an 鈥渁rrangement鈥� includes a series of arrangements or transactions making it possible to consider the overall transactions or arrangements as a whole when considering what the purpose of the arrangement is or an 鈥渁rrangement鈥� can be a part of an arrangement that exists within a wider whole and the focus can be on that part of the overall arrangement when considering its purpose.

鈥淎ssumed taxable total profits鈥� and 鈥淎ssumed total profits鈥�, in relation to a CFC, are defined at INTM239200

鈥淏anking business鈥� means the business of:-

• banking, deposit-taking, money-lending or debt factoring, or
• any activity similar to an activity falling within the above bullet point.

A 鈥淐FC鈥� is a non-UK resident company which is controlled by a UK resident person or persons (but see INTM236100 for certain cases in which a non-UK resident company is to be taken to be a CFC even though it is not controlled by a UK resident person or persons).

鈥淭he CFC charge鈥� is defined at INTM194100

鈥淐hargeable company鈥� is defined at INTM194500

鈥淐hargeable profits鈥� is defined at INTM194200

鈥淐ompany鈥� is to be read subject to TIOPA10/S371VE (see INTM236500) which applies Part 9A to unincorporated cells of protected cell companies or incorporated cells of incorporated cell companies as if the individual cells were non-UK resident companies. Otherwise 鈥渃ompany鈥� takes its normal Corporation Taxes Act definition at .

鈥淐ompany tax return鈥� means a return required to be made under .

鈥淐ontract of insurance鈥� has the meaning given by ).

鈥淐ontrol鈥� is defined at INTM236000

鈥淭he corporation tax assumptions鈥� are defined at INTM239300

鈥淐reditable tax鈥� is defined at INTM230000

鈥淭he HMRC Commissioners鈥� means the Commissioners for Her Majesty鈥檚 Revenue and Customs.

鈥淚nsurance business鈥� means the business of effecting or carrying out of contracts of insurance, including the investment of premiums received.

鈥淚ntellectual property鈥� means:

• any patent, trade mark, registered design, copyright or design right, or
• any licence or other right in relation to anything falling within the above bullet point.

鈥淚nterest鈥�, as in interest in a company, is defined at INTM227000

鈥淭he local tax amount鈥�, in relation to a CFC, is defined at INTM226150

鈥淣on-trading finance profits鈥� are defined at INTM248400

鈥淣on-trading income鈥� means income which is not trading income (see trading income).

鈥淧roperty business profits鈥� are defined at INTM248550

鈥淩elevant finance lease鈥� is defined at INTM248600 and includes any part of such a lease.

鈥淩elevant interest鈥� is defined at INTM227000

鈥淭ax advantage鈥� has the meaning given by and includes at CTA10/1139(2)(da) the avoidance or reduction of a CFC charge or assessment to a charge.

鈥淭rading finance profits鈥� are defined at INTM248450

鈥淭rading income鈥�, in relation to a CFC, means income brought into account in determining the CFC鈥檚 trading profits for the accounting period in question.

鈥淭rading profits鈥�, in relation to a CFC, means any profits included in the CFC鈥檚 assumed total profits for the accounting period in question on the basis that they would be chargeable to corporation tax under .

鈥淯K connected capital contribution鈥�, in relation to a CFC, means any capital contribution to the CFC made (directly or indirectly) by a UK resident company connected with the CFC (whether in relation to an issue of shares in the CFC or otherwise).

鈥淯K permanent establishment鈥�, in relation to a non-UK resident company, means a permanent establishment which the company has in the United Kingdom and through which it carries on a trade in the United Kingdom.