WebJan 1, 2013 · Excluded Territories Exemption – this applies to exempt CFCs resident in certain territories, subject to conditions. Its purpose is to exempt those CFCs which constitute a low risk of UK profit diversion partly on account of their territory of residence but also by looking at the type of income the CFC can receive and any amounts it may ... WebChapter 11, introduced by TIOPA10/S371KA, provides for the “excluded territories exemption” (ETE). The ETE is an entity level exemption (see INTM224000).Its purpose is to exempt those CFCs ...
International Manual - GOV.UK
WebINTM224960 - Restricted income - Category A. INTM224965 - Category A permanent establishment(s) of a CFC. INTM224970 - Restricted income - Category B. INTM224980 - Restricted income - Category C ... WebA limitation is imposed by TIOPA10/S371KD on the amount of a CFC’s income falling within four categories if it is to qualify for the excluded territories exemption (ETE) (the threshold test). nick jr coming up next bumpers 2012
International Manual - GOV.UK
http://taxnews.lexisnexis.co.uk/TaxNewsLive/Members/BreakingNewsFullText.aspx?id=3759 1.—(1) These Regulations may be cited as the Controlled Foreign Companies (Excluded Territories) Regulations 2012 and come into force on 1st January 2013. (2) These Regulations have effect for accounting periods of CFCs beginning on or after 1st January 2013. See more 2.In these Regulations— “TIOPA 2010” means the Taxation (International and Other Provisions) Act 2010; “the Schedule” means the Schedule to these Regulations. See more 5.For the purposes of Chapter 11 of Part 9A of TIOPA 2010, Part 2 of the Schedule specifies a further requirement which must be met in order for the excluded territories exemption to apply for a CFC’s accounting period. Regulations 3 … See more 3.A territory listed in Part 1 of the Schedule is an excluded territory for the purposes of Chapter 11 of Part 9A of TIOPA 2010 (the … See more 4.—(1) For the purposes of Chapter 11 of Part 9A of TIOPA 2010, the requirements of section 371KB(1)(b) and (c) of that Act do not have to be … See more WebAug 6, 2012 · The regulations provide the list of excluded territories for the purposes of the ETE, and set out a simplified ETE that is available for CFCs in Australia, Canada, France, Germany, Japan and the US. These are major trading partners that have tax regimes broadly equivalent to the UK. “In essence, subject to some detailed rules, companies ... novi whirlpool tub owners manual