Section 931CA — Corporation Tax Act 2009: Further exemption where distribution received from CFC

Further exemption where distribution received from CFC 931CA 1 Subsection (2) applies if—

a under Part 9A of TIOPA 2010 (controlled foreign companies), the CFC charge is charged in relation to a CFC's accounting period, b a dividend or other distribution of the CFC is received in an accounting period (for corporation tax purposes) of the recipient in which the recipient is a small company, c the whole or a part of the distribution is paid in respect of profits which are chargeable profits of the CFC for its accounting period mentioned in paragraph (a),

and d the requirements of section 931B(b) to (d) are met in relation to the distribution.

2 The distribution is exempt.

3 If part of the distribution is not paid in respect of chargeable profits—

a for the purposes of this Part and Part 2 of TIOPA 2010 that part of the distribution is treated as a separate distribution, and b subsection (2) does not apply to that separate distribution.

4 In this section references to chargeable profits of the CFC are limited to chargeable profits so far as apportioned to chargeable companies at step 3 in section 371BC(1) of TIOPA 2010.