CONTROLLED FOREIGN COMPANIES. The Company does not have and never has had an interest in a controlled foreign company within the meaning of section 747 of the TA such that all or any of the chargeable profits of the controlled foreign company have been or will or may be apportioned to the Company.
CONTROLLED FOREIGN COMPANIES. No notice of the making of a direction under section 747, ICTA 1988 has been received by the Company and no circumstances exist which would entitle the Inland Revenue to make such a direction or to apportion any profits of a controlled foreign company to the Company pursuant to section 752, ICTA 1988.
CONTROLLED FOREIGN COMPANIES. No notice of the making of a direction under section 747, TA 88 has been received by the Company and no circumstances exist which would entitle the Inland Revenue to make such a direction or to apportion any profits of a controlled foreign company to the Company pursuant to section 752, TA 88 .
CONTROLLED FOREIGN COMPANIES. (1) The Company has no interest in the share capital of any company not resident in the United Kingdom for taxation purposes (or which is treated for the purposes of any double taxation convention as not being so resident) which is controlled by persons resident in the United Kingdom for taxation purposes and in which the Company has ten per cent (10%) or more of the voting rights (“controlled foreign company”).
CONTROLLED FOREIGN COMPANIES. 1.61 No notice of the making of a direction under ICTA s 747 (Imputation of chargeable profits and creditable Tax of controlled foreign companies) has been received by any of the Group members and no circumstances exist which would entitle the Inland Revenue to make a direction and to apportion any profits of a controlled foreign company to any of the Group members under ICTA s 752 (Apportionment of chargeable profits and creditable Tax).
CONTROLLED FOREIGN COMPANIES. The Company has not been liable to Tax on the undistributed profits of any overseas subsidiary where the Company has a shareholding in excess of ten per cent. of such subsidiary.
CONTROLLED FOREIGN COMPANIES. No Group Member has had nor had it had within the six year period ending on Completion an interest in a controlled foreign company as defined in Chapter IV of Part XVII of ICTA 1988 where an apportionment of the chargeable profits of the controlled foreign company has been made or is due to be made to that Group Member pursuant to section 747(3) of ICTA 1988.
CONTROLLED FOREIGN COMPANIES. 6.2.1. The Disclosure Letter contains full details of any company, in the share capital of which the Company has an interest, which is not resident in the United Kingdom for Taxation purposes (or which is treated for the purposes of any double taxation convention as not being so resident) which is controlled by persons resident in the United Kingdom for Taxation purposes and in which the Company has 10 per cent or more of the voting rights (a "controlled foreign company").
CONTROLLED FOREIGN COMPANIES. The Company does not hold and has never held, directly or indirectly, any interest in a controlled foreign company which has resulted in any liability to Tax pursuant to Part 9A of Taxation (International and Other Provisions) Act 2010.
CONTROLLED FOREIGN COMPANIES. No notice of the making of a direction under s.747 Taxes Act 1988 (imputation of chargeable profits and creditable tax of controlled foreign companies) has been received by any UK Company and no circumstances exist which would entitle the Inland Revenue to make such a direction and to apportion any profits of a controlled foreign company to any UK Company pursuant to s.752 Taxes Act 1988 (apportionment of chargeable profits and creditable tax.
