Section 54 Non-UK resident company: receipts of interest, dividends or royalties

United Kingdom

(1)

This section applies if—

(a)

a non-UK resident company carries on a trade in the United Kingdom, and

(b)

tax-exempt receipts of interest, dividends or royalties arise to the company.

(2)

The receipts are not to be excluded from the profits of the trade so as to give rise to a loss to be deducted under F1section 37 F2, 45, 45A or 45B .

(3)

For the purposes of subsection (1) a receipt is “tax-exempt” if it has been treated as tax-exempt under arrangements having effect under section 2 of TIOPA 2010.

Annotations

Textual amendments

F1: Words in s. 54(2) substituted (17.7.2012) by Finance Act 2012 (c. 14), Sch. 16 para. 217
F2: Words in s. 54(2) substituted (with effect in accordance with Sch. 4 para. 190 of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 4 para. 151

Notes on Part 4

Modifications

C1: Pt. 4 modified (with effect in accordance with reg. 1(2) of the amending S.I.) by The Risk Transformation (Tax) Regulations 2017 (S.I. 2017/1271), regs. 1(1), 10
C2: Pt. 4 excluded (14.7.2022) by Energy (Oil and Gas) Profits Levy Act 2022 (c. 40), s. 1(5)(e) (with ss. 15(1), 16(1))