Paragraph 3 I1

After subsection (3) insert—

“(3A)

A non-UK resident company which carries on a UK property business is chargeable to corporation tax on income on all its profits that are—

(a)

profits of that business, or

(b)

profits arising from loan relationships or derivative contracts that the company is a party to for the purposes of that business.

(3B)

A non-UK resident company which has other UK property income is chargeable to corporation tax on income on all its profits that—

(a)

consist of that income, or

(b)

are profits arising from loan relationships or derivative contracts that the company is a party to for the purposes of enabling it to generate that income.”