Controlled Foreign Companies

The motive test (ICTA 1988, s. 748(3)) reviewed by Colin Davis, CIOT Technical Officer. This article appeared in the July 2003 issue of Tax Adviser. To download the article in Adobe (pdf) format, please click on the link below. The first case to be litigated on the motive test (Association of British Travel Agends Ltd v IR Commrs, Sp C 359 ('the ABTA case') came before the special commissioners last autumn and the Inland Revenue have published draft guidance on this test. This provides a good opportunity to review the test and the ABTA case.

Technical Department
020 7235 9381

July 2003 by