Paragraph 39

(1)

Section 938M (group mismatch schemes: controlled foreign companies) is amended as follows.

(2)

In subsection (1) for the words from the beginning to “company” substitute “ Section 371SL(1) of TIOPA 2010 (assumption that a CFC ”.

(3)

In subsection (2)—

(a)

for “chargeable profits” substitute “ assumed taxable total profits ”, and

(b)

for “Chapter 4 of Part 17 of ICTA” substitute “ Part 9A of TIOPA 2010 ”.