Section 179 Compensating payment if advantaged person is controlled foreign company

the actual provision is provision made or imposed in relation to a CFC,

for the purpose of determining the CFC's assumed taxable total profits for an accounting period, the CFC's profits and losses are to be calculated in accordance with section 147(3) or (5) in the case of that provision,

in relation to the accounting period, sums are charged on chargeable companies at step 5 in section 371BC(1), and

in consequence of the application of section 147(3) or (5) as mentioned in paragraph (b), the total of those sums is more than it would otherwise be.

references to the advantaged person in sections 176(3)(a) and (b) and 177(2), (3) and (4)(b) include a reference to any of the F3chargeable companies on which a sum is charged, and

references to corporation tax include a reference to F4the CFC charge.