Section 18IA — Corporation Tax Act 2009: The excluded territories exemption

The excluded territories exemption 18IA 1 Chapter 11 of Part 9A of TIOPA 2010 (controlled foreign companies: the excluded territories exemption) applies for the purposes of section 18G(1)(c) with the following modifications.

2 Sections 371KB(1)(b)(iii) and 371KH are to be omitted.

3 Section 371KC is to be omitted and the assumption set out in section 18I(3)(b) above in relation to the CFC's residence is to be applied instead; and references to “the CFC's territory” are to be read accordingly.

4 Section 371KD(3) is to be omitted and references to a CFC's accounting profits for an accounting period are to be read as references to the adjusted relevant profits amount.

5 Section 371KE(2)(b) is to be omitted.

6 Section 371KF is to be omitted.

7 In section 371KG(3) the reference to the CFC's equity or debt is to be read as a reference to company X's equity or debt (ignoring the assumption in section 18I(3)(a) above).

8 Section 371KI(2) and (3) is to be omitted.

9 In section 371KJ—

a in subsection (2)(a), the reference to intellectual property held by the CFC is to be read as a reference to intellectual property held by company X (ignoring the assumption in section 18I(3)(a) above),

and b in subsections (2)(b) and (c) and (4), references to the CFC are to be read as references to company X (ignoring that assumption).