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PART 2 U.K.Digital services tax

Charge to taxU.K.

49Section 48: meaning of “relevant operating expenses”U.K.

(1)This section supplements section 48.

(2)The “relevant operating expenses” of a group, in relation to a specified category of revenues, means any expenses of a member of the group attributable to the earning of UK digital services revenues within the specified category, except excluded expenses.

(3)Excluded expenses” means any expenses—

(a)in respect of interest (or anything equivalent, from a commercial perspective, to interest),

(b)attributable to the acquisition of a business or part of a business,

(c)occurring otherwise than in the normal course of business,

(d)resulting from a change in the valuation of any tangible or intangible asset, or

(e)in respect of any tax (arising under the law of any territory).

(4)Where expenses are attributable to—

(a)the earning of UK digital services revenues within the specified category, and

(b)anything else,

the expenses are to be treated as relevant operating expenses to such extent as is just and reasonable.

(5)In this section “specified” has the meaning given by section 48.