{
  "url": "https://openlegislation.uk/controlled-foreign-companies-excluded-countries-amendment-no-2-regulations-2005/regulation-2",
  "json_url": "https://openlegislation.uk/controlled-foreign-companies-excluded-countries-amendment-no-2-regulations-2005/regulation-2.json",
  "legislation": "uksi/2005/186",
  "legislation_title": "The Controlled Foreign Companies (Excluded Countries) (Amendment No. 2) Regulations 2005",
  "legislation_url": "https://openlegislation.uk/controlled-foreign-companies-excluded-countries-amendment-no-2-regulations-2005",
  "path": "regulation/2",
  "kind": "regulation",
  "number": "2",
  "heading": "Amendment of the Controlled Foreign Companies (Excluded Countries) Regulations 1998",
  "text": "(1) Amend regulation 4 of the Controlled Foreign Companies (Excluded Countries) Regulations 1998 (limitation on apportionment of chargeable profits of a controlled foreign company — conditions to be satisfied) as follows.\n(2) Before paragraph (1) insert the following paragraphs—\n“(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.\n(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.\nIn this paragraph—\n“arrangement” means an arrangement of any kind, whether in writing or not; and\n“United Kingdom tax” means corporation tax or any tax chargeable as if it were corporation tax.”.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "footnote",
      "label": "f1",
      "text": "S.I. 1998/3081. There are amendments which are not relevant for present purposes."
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/2005/186/regulation/2",
    "retrieved_at": "2026-10-29T05:11:00.854372+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."
}