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  1. Home
HMRC internal manual

International Manual

From:
HM Revenue & Customs
Published
9 April 2016
Updated:
7 April 2025 - See all updates
  1. Back to contents
  2. INTM190000

INTM239000 - Controlled Foreign Companies: Assumed Taxable Total Profits, Assumed Total Profits and the Corporation Tax Assumptions: contents

TIOPA10/Part 9A uses the terminology, 鈥淎ssumed Taxable Total Profits鈥, 鈥淎ssumed Total Profits鈥 and 鈥淭he Corporation Tax Assumptions鈥. TIOPA10/Part 9A/Chapter 19 explains what is meant by these expressions.

  1. INTM239100
    Introduction
  2. INTM239200
    Assumed Taxable Total Profits and Assumed Total Profits
  3. INTM239300
    Corporation Tax Assumptions
  4. INTM239400
    UK Residence
  5. INTM239500
    Example
  6. INTM239600
    Close Company
  7. INTM239700
    Claims and Elections
  8. INTM239800
    Claims and Elections - disapplication of assumption
  9. INTM239900
    Elections under Section 9A of CTA 2010
  10. INTM240000
    Elections for Leases to be treated as Long Funding Leases
  11. INTM240100
    Intangible Fixed Assets
  12. INTM240200
    Group Relief
  13. INTM240300
    Capital Allowances
  14. INTM240400
    Unremittable Overseas Income
  15. INTM240500
    Tax advantages
  16. INTM240600
    Disguised Interest
  17. INTM240700
    Shares Accounted for as Liabilities
  18. INTM240800
    Double Taxation Relief - Counteraction Notices
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