[18O Transfers of foreign permanent establishment business]
Corporation Tax Act 2009 (2009 c 4) | Legislation

[18O  Transfers of foreign permanent establishment business]

[(1)     This section applies if—

(a)     business carried on by a company (“the transferor”) through a permanent establishment in a territory outside the United Kingdom is transferred to a connected company that is (or later becomes) a UK resident company (“the transferee”), and

(b)     there is a transferred total opening negative amount in relation to the business transferred.

(2)     In a case where the transferor had not made an election under section 18A before the transfer took place, or such an election had not had effect before that time, the “transferred total opening negative amount” is the amount that would have been the total opening negative amount in the case of the transferor at the beginning of the transferor's first relevant accounting period if—

(a)     the only business carried on by the transferor was the business transferred,

(b)     the transfer

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