{
  "url": "https://openlegislation.uk/controlled-foreign-companies-designer-rate-tax-provisions-regulations-2000/note",
  "json_url": "https://openlegislation.uk/controlled-foreign-companies-designer-rate-tax-provisions-regulations-2000/note.json",
  "legislation": "uksi/2000/3158",
  "legislation_title": "The Controlled Foreign Companies (Designer Rate Tax Provisions) Regulations 2000",
  "legislation_url": "https://openlegislation.uk/controlled-foreign-companies-designer-rate-tax-provisions-regulations-2000",
  "path": "note",
  "kind": "note",
  "number": null,
  "heading": "Explanatory note",
  "text": "(This note is not part of the Regulations)\nSection 750A of the Income and Corporation Taxes Act 1988 (inserted by paragraph 3 of Schedule 31 to the Finance Act 2000) (“section 750A” and “the 1988 Act” respectively) provides that, where in any accounting period—\na company is resident in a particular territory outside the United Kingdom for the purposes of Chapter IV of Part XVII of the 1988 Act (controlled foreign companies),\nthe local tax of the territory concerned in respect of the profits of the company in that accounting period is equal to or greater than three-quarters of the corresponding United Kingdom tax on those profits, and\nthat local tax is determined under designer rate tax provisions,\nthe company shall be taken for the purposes of that Chapter to be subject to a lower level of taxation in that territory in that accounting period than the corresponding United Kingdom level of taxation.\nSection 750A defines designer rate tax provisions as meaning provisions which—\nappear to the Board of Inland Revenue to be designed to enable companies to exercise significant control over the amount of tax which they pay, and\nare specified in regulations made by the Board.\nThese Regulations specify for the purposes of section 750A provisions contained in the tax legislation of Guernsey, Jersey, the Isle of Man and Gibraltar.\nThe Regulations have effect in relation to any accounting period of a company resident outside the United Kingdom which begins on or after 6th October 1999. Authority for the retrospective effect of the Regulations is conferred by subsection (4) of section 750A.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/2000/3158/note",
    "retrieved_at": "2026-10-29T08:10:00.897676+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}