Regulation 2 Amendment of the Controlled Foreign Companies (Excluded Countries) Regulations 1998

Amend regulation 4 of the Controlled Foreign Companies (Excluded Countries) Regulations 1998^f1 (limitation on apportionment of chargeable profits of a controlled foreign company — conditions to be satisfied) as follows.

Before paragraph (1) insert the following paragraphs—

“(A1)

Paragraph (A2) specifies the condition which is required to be satisfied as respects an accounting period by a controlled foreign company, wherever it is resident in that accounting period.

(A2)

The condition specified in this paragraph is that, during the accounting period, the company has not been involved in a scheme or arrangement the purpose, or one of the main purposes, of which is to achieve a reduction in United Kingdom tax.

• In this paragraph—

• “arrangement” means an arrangement of any kind, whether in writing or not; and

• “United Kingdom tax” means corporation tax or any tax chargeable as if it were corporation tax.”.