Introduction Summary
1.Section 220 introduces Schedule 47 which ensures the Controlled Foreign Companies (CFC) regime at Part 9A of the Taxation (International and Other Provisions) Act 2010 (TIOPA) operates as intended. It makes amendments to Part 2 (double taxation relief), Part 6 (tax arbitrage) and Part 9A (controlled foreign companies) TIOPA. The above amendments, subject to one transitional rule, will come into force on 1 January 2013.