Guidance

Supplementary pages CT600B: controlled foreign companies and foreign permanent establishment exemptions, hybrid and other mismatches

How to complete supplementary pages CT600B and what information you need to include.

From:
HM Revenue & Customs
Published
30 September 2022
Last updated
2 January 2024 — See all updates

When to complete

Complete these supplementary pages if your company held a relevant interest of 25% in a controlled foreign company at any time in this accounting period, and the accounting period of the controlled foreign company either:

  • ended at the same time as the company’s accounting
  • ended within the company’s accounting period

You should also complete these supplementary pages if any of the following apply to the company, it:

Do not include any controlled foreign company that satisfies the Tax Exemption, the Excluded Territories Exemption or the Low Profit Margin Exemption.

Company information

B1 Company name

Enter the company name.

B2 Tax reference

Enter the company’s 10-digit Unique Taxpayer Reference.

Period covered by this supplementary page (cannot exceed 12 months)

B3

Enter the start date using the format DD MM YYYY.

B4

Enter the end date of the accounting period using the format DD MM YYYY.

Controlled foreign companies and foreign permanent establishment exemptions

B5 Controlled foreign company table

A Name of controlled foreign company

Enter the full name of the controlled foreign company.

B Territory of residence

Enter the territory of residence of the controlled foreign company as determined under chapter 20, Part 9A of the Taxation (International and Other Provisions) Act 2010

C Type of exemption due (if any)

A company that is a chargeable company (as defined in section 371BD of the Taxation (International and Other Provisions) Act 2010) must make an entry where all of its profits are excluded from charge because:

  • none of chapters 4 to 8 apply — enter gateway chapter 3 in column C
  • although one or more of Chapters 4 to 8 needs to be considered, no chargeable profits arise — enter the relevant chapter number from 4 to 8 in column C
  • profits from qualifying loan relationships are fully exempt under chapter 9 — enter chapter 9 in column C
  • the controlled foreign company is exempted by the Exempt Period Exemption or the Low Profits Exemption — enter the relevant exemption in column C

Do not complete columns D to J if there’s no controlled foreign company charge by virtue of chapters 3 to 8, or an exemption applies.

D Percentage of apportionable profits and creditable tax

Enter the percentage of the controlled foreign company’s chargeable profits apportioned to the chargeable company. This is defined as P% in section 371BC of the Taxation (International and Other Provisions) Act 2010.

This will usually be the percentage of ordinary share capital held directly or indirectly by the UK company (but not by associated or connected persons). In all other circumstances, the appropriate percentage should be calculated on a just and reasonable basis. If profits are partially exempted by the operation of any chapter (including chapter 9) this should not be recorded in column D.

E Chargeable profits

Enter the profits that pass through the controlled foreign company charge gateway in chapters 3 to 8, calculated in accordance with section 371BA of the Taxation (International and Other Provisions) Act 2010. Profits subject to charge under chapter 5 may be wholly or partially exempted by chapter 9 on the making of a claim on the tax return. The figure entered in Column E should be before any such claim.

F Tax on chargeable profits

Enter the amount of tax (the controlled foreign company charge) due in respect of the chargeable company’s share of the controlled foreign company’s chargeable profits.

G Creditable tax

Enter the amount of tax already paid on the chargeable profits that is deductible.

H Reliefs in terms of tax (exemption claimed under Chapter 9)

Enter the amount of tax on any profits excluded by the making of a claim under chapter 9 of Part 9A of the Taxation (International and Other Provisions) Act 2010.

I ACT as restricted

Enter the amount of any unrelieved surplus Advance Corporation Tax under section 32 of the Finance Act 1998.

J Controlled foreign company charge due

Enter the amount of controlled foreign company charge due.

B10 Total tax on chargeable profits

Enter the total of column F.

B15 Total creditable tax

Enter the total of column G.

B20 Total reliefs in terms of tax

Enter the total of column H.

B25 Total ACT as restricted

Enter the total of column I.

B30 Total controlled foreign company charge due

Enter the total of column J.

Enter the figure from box B30 into box 490 of your CT600 form.

B35 Put an X in the box if this is the first period where an election for foreign permanent establishment exemption applies

Enter X if this is the first period where an election for foreign permanent establishment exemption applies. Read International Manual INTM281010: Foreign permanent establishments of UK companies for more information.

Hybrid and other mismatches

B40 to B85 should be completed for any return submissions made for the first time from April 2022, if applicable. You are not required to complete these boxes if you are submitting an amended return.

B40 The company is a hybrid entity

Enter X if the company is a hybrid entity. For more information read:

B45 There were any transactions with hybrid entities in the same control group as this company

Enter X if there were any transactions:

  • involving a payment or quasi payment to the company from a hybrid entity in the same control group
  • from the company to a hybrid entity in the same control group

Read International Manual INTM550610: Hybrids: definition of key terms: control groups and related persons for more information.

B50 There were any hybrid or otherwise impermissible deduction/non-inclusion mismatches in connection with a financial instrument.

If the other conditions in section 259CA of the Taxation (International and Other Provisions) Act 2010 are also met, enter X if there was a deduction or non-inclusion mismatch in connection with a financial instrument. For more information read:

B55 There was an excessive permanent establishment (PE) deduction

If the other conditions in section 259FA of the Taxation (International and Other Provisions) Act 2010 are also met, enter X if there was an excessive permanent establishment deduction. For more information read International Manual INTM554000: Hybrids: transfers by UK permanent establishment of a multinational company.

B60 There has been a multinational payee deduction or non-inclusion mismatch

If the other conditions in section 259HA of the Taxation (International and Other Provisions) Act 2010 are also met, enter X if there was multinational payee deduction or non-inclusion mismatch. For more information read:

B65 There has been a counteraction under Part 6A Taxation (International and Other Provisions) Act 2010 (TIOPA 2010)

Enter X if there has been a counteraction which affects the amount of tax payable in the period under any of the chapters of Part 6A of the Taxation (International and Other Provisions) Act 2010.

B70 Total counteraction

Enter the amount of the total counteraction if you have entered X in box B65. This figure should be noted in your computations.

Do not include amounts that have been deducted in the current period only because they are matched by Dual Inclusion Income.

B75 Total section 259LA TIOPA 2010 deduction

Enter the amount deducted due to an amount of ordinary income arising outside the permitted period. This figure should be noted in your computations. For more information read:

B80 Total claim for allocation of dual inclusion income (DII) surplus that the company has made

Enter the amount of the allocation claim made by you to another group company. For more information read:

B85 Total claim of DII surplus that the company has consented to

Enter the amount of the allocation claim from another group company that you have consented to. Read section 259ZMB of the Taxation (International and Other Provisions) Act 2010 for more information.

Updates to this page

Published 30 September 2022
Last updated 2 January 2024 + show all updates

  1. Added translation

  2. Information about when to complete boxes B40 to B85 has been added to the 'Hybrid and other mismatches' section.

  3. First published.

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