[18A Exemption for profits or losses of foreign permanent establishments]
Corporation Tax Act 2009 (2009 c 4) | Legislation

[Chapter 3A
UK Resident Companies: Profits of Foreign Permanent Establishments]

[Exemption]

[18A  Exemption for profits or losses of foreign permanent establishments]

[(1)     If a . . . 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.

[(2A)     But profits and losses are not to be left out of account as mentioned in subsection (2) so far as they are [or, if the company were non-UK resident, would be—

(a)     profits or losses of the company's trade of dealing in or developing UK land (see section 5B),

(b)     profits or losses of the company's UK property business,

(c)     profits consisting of the company's other UK property income, or

(d)     profits or losses arising from loan relationships or derivative contracts that the company is a party to for the purposes of its UK property business or for the purposes

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