Part 1 Amendments of CTA 2009
Finance Act 2011 (2011 c 11) | Legislation

SCHEDULE 13 Profits of Foreign Permanent Establishments etc

Section 48

Part 1 Amendments of CTA 2009

1

CTA 2009 is amended as follows.

2

In section 1(1)(c) (overview of Act), for “Chapter 4†substitute “Chapters 3A and 4â€.

3

In section 5(1) (territorial scope), insert at the end “(but see Chapter 3A for an exemption from charge in respect of profits of foreign permanent establishments)â€.

4

After section 18 insert—

“Chapter 3A
UK Resident Companies: Profits of Foreign Permanent Establishments
Exemption
18A Exemption for profits or losses of foreign permanent establishments

(1)     If a UK resident company makes an election under this section, exemption adjustments are to be made at the appropriate stages in calculating the taxable total profits of the company for each relevant accounting period.

(2)     For that purpose “exemption adjustments†means any such adjustments as are appropriate to secure that there are left out of account any profits and losses taken into account in arriving at the foreign permanent establishments amount in relation to any relevant accounting period.

(3)     In this Chapter “relevant accounting periodâ€, in relation to a company by which an election is made under this section, means

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