| INTM208010 | Introduction to the
motive test |
| INTM208020 | The conditions of the
motive test |
| INTM208030 | The transaction leg of
the motive test: transactions reducing United Kingdom tax |
| INTM208040 | The transaction leg of
the motive test: statutory definition |
| INTM208050 | The transaction leg of
the motive test: are the results of the transaction(s) reflected in
the controlled foreign company's profits for an accounting
period? |
| INTM208060 | The transaction leg of
the motive test: reduction in United Kingdom tax? |
| INTM208070 | The transaction leg of
the motive test: reduction in United Kingdom tax more than
minimal? |
| INTM208080 | The transaction leg of
the motive test: motive element |
| INTM208090 | The diversion of
profits leg of the motive test |
| INTM208100 | The diversion of
profits leg of the motive test: statutory definition |
| INTM208110 | The diversion of
profits leg of the motive test: are there receipts reflected in the
controlled foreign company's profits for an accounting period? |
| INTM208120 | The diversion of
profits leg of the motive test: in the absence of the controlled
foreign company (and any 'related company'), would it be reasonable
to suppose that the whole or a substantial part of those receipts
would have been received by a United Kingdom person? |
| INTM208130 | The diversion of
profits leg of the motive test: related company |
| INTM208140 | The diversion of
profits leg of the motive test: United Kingdom company |
| INTM208150 | The diversion of
profits leg of the motive test: would the United Kingdom person
have paid more, or been entitled to less relief from, United
Kingdom tax? |
| INTM208160 | The diversion of
profits leg of the motive test: motive element |
| INTM208170 | Application of motive
test: overview |
| INTM208180 | Application of motive
test: 'marginal and isolated failure' of exempt activities and
excluded countries exemptions |
| INTM208190 | Application of motive
test: newly-established overseas business |
| INTM208200 | Application of motive
test: incorporation of foreign branch |
| INTM208210 | Application of motive
test: United Kingdom takeover of overseas group - 'period of
grace' |
| INTM208220 | Application of motive
test: holding companies - background |
| INTM208230 | Application of motive
test: holding companies - 21 March 2000 example |
| INTM208240 | Application of motive
test: holding companies - avoidance of United Kingdom or foreign
tax |
| INTM208250 | Application of motive
test: holding companies - conduit companies |
| INTM208260 | Application of motive
test: Venture Capital Limited Partnerships |
| INTM208270 | Application of motive
test: loan relationships legislation |
| INTM208280 | Application of motive
test: examples - 'marginal and isolated failure' of exempt
activities and excluded countries exemptions |
| INTM208290 | Application of motive
test: examples - United Kingdom takeover of overseas group |
| INTM208300 | Application of motive
test: examples - locally based traders failing the exempt
activities test |
| INTM208310 | Application of motive
test: examples - intra-group service providers failing the exempt
activities test |
| INTM208320 | Application of motive
test: examples - controlled foreign company’s profits
effectively subject to tax in the United Kingdom |
| INTM208330 | Application of motive
test: examples - captive insurance companies |
| INTM208340 | Application of motive
test: examples - 'money boxes' |
| INTM208350 | Application of motive
test: examples - holding companies |
