Section 431A Foreign permanent establishment exemptionF1

(1)

Subsection (2) applies if—

(a)

an election under section 18A of CTA 2009 has effect in relation to a company, and

(b)

the company carries on any trade which consists of, or includes, the working of a source of mineral deposits.

(2)

That trade so far as carried on through one or more permanent establishments outside the United Kingdom is treated for the purposes of this Part as a trade—

(a)

separate from any other trade of the company, and

(b)

all the profits and gains from which are not, or (if there were any) would not be, chargeable to tax.

Annotations

Textual amendments

F1: Ss. 431A-431C inserted (with effect in accordance with s. 67(9) of the amending Act) by Finance Act 2014 (c. 26), s. 67(7)