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Home / Simons-Taxes /Personal and employment tax /Part E1 Income tax /Division E1.11 Transfer of assets abroad /Individuals with power to enjoy income as a result of transfer of assets abroad / E1.1111 Charge under ITA 2007, s 720—reduction where person abroad is a CFC
Commentary

E1.1111 Charge under ITA 2007, s 720—reduction where person abroad is a CFC


Personal and employment tax

Where a non-UK resident company is controlled by persons resident in the UK, the profits of that company for an accounting period may, if certain conditions are met, be apportioned to its UK shareholders. In such a case, the non-resident company is designated a controlled foreign company (CFC), and the amounts of its profits apportioned to any company resident in the UK are charged to corporation tax on that company1.

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