[259FB Counteraction of the excessive PE deduction]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[Counteraction]

[259FB  Counteraction of the excessive PE deduction]

[(1)     For corporation tax purposes, the excessive PE deduction may not be deducted from the company's income for the relevant PE period unless it is deducted from dual inclusion income for that period.

(2)     So much of the excessive PE deduction (if any) as, by virtue of subsection (1), cannot be deducted from the company's income for the relevant PE period—

(a)     is carried forward to subsequent accounting periods of the

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