15U.K.In section 15 (plant and machinery allowances: qualifying activities), after subsection (2) insert—
“(2A)A business carried on through one or more permanent establishments outside the United Kingdom by a company in relation to which an election under section 18A of CTA 2009 has effect—
(a)is an activity separate from any other activity of the company, and
(b)is to be regarded as an activity all the profits and gains from which are not, or (if there were any) would not be, chargeable to tax.”