Part 1 Interpretation

SCHEDULE 19 Large Businesses: Tax Strategies and Sanctions

Section 161

Part 1 Interpretation

Purpose of Part 1

1

This Part defines terms for the purposes of this Schedule.

“Relevant bodyâ€

2

(1)     “Relevant body†means a UK company or any other body corporate (wherever incorporated), but does not include a limited liability partnership.

(2)     A relevant body is a “foreign†relevant body (or member of a group or sub-group) if it is incorporated outside the United Kingdom.

“UK companyâ€

3

(1)     “UK company†means a company which is (or is treated as if it is) formed and registered under the Companies Act 2006, unless it falls within sub-paragraph (2).

(2)     The term “UK company†does not include a company which is—

(a)     an open-ended investment company within the meaning of section 613 of CTA 2010, or

(b)     an investment trust within the meaning of section 1158 of CTA 2010.

“UK permanent establishmentâ€

4

(1)     “UK permanent establishment†means a permanent establishment in the United Kingdom of a foreign relevant body.

(2)     In sub-paragraph (1) “permanent establishment†has the same meaning as it has for the purposes of the Corporation Tax Acts (see section

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