{
  "url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-167",
  "json_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-167.json",
  "legislation": "ukpga/2010/8",
  "legislation_title": "Taxation (International and Other Provisions) Act 2010",
  "legislation_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010",
  "path": "section/167",
  "kind": "section",
  "number": "167",
  "heading": "Small and medium-sized enterprises: exceptions from exemption",
  "text": "(1) Subsections (2) and (3) set out exceptions to section 166(1).\n(2) The first exception is if the small or medium-sized enterprise elects for section 166(1) not to apply in relation to the chargeable period.\nAny such election is irrevocable.\n(3) The second exception is if—\n(a) the other affected person, or\n(b) a party to a relevant transaction,\nis, at the time when the actual provision is or was made or imposed, a resident of a non-qualifying territory (whether or not that person is also a resident of a qualifying territory).\n(4) For the purposes of subsection (3)—\n(a) a “party to a relevant transaction” is a person who, if the actual provision is or was imposed by means of a series of transactions, is or was a party to one or more of those transactions, and\n(b) “qualifying territory” and “non-qualifying territory” are defined in section 173.\n(5) In subsection (3) “resident”, in relation to a territory—\n(a) means a person who, under the law of that territory, is liable to tax there by reason of the person's domicile, residence or place of management, but\n(b) does not include a person who is liable to tax in that territory in respect only of income from sources in that territory or capital situated there.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "C",
      "label": "C1",
      "text": "Ss. 166-171 excluded (1.4.2010 with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), ss. 542(2), 1184(1) (with Sch. 2)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/8/section/167",
    "retrieved_at": "2026-10-29T09:10:17.008829+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}