Income and Corporation Taxes Act 1988

12(1)It is to be assumed that the EEA company is resident in the United Kingdom throughout the loss period.

(2)But this does not require it to be assumed—

(a)that there is any change in the place or places at which the EEA company carries on its activities (although see paragraph 13), or

(b)that the EEA company ceases to be resident in the United Kingdom at the end of the loss period.

(3)It is to be assumed that the EEA company becomes resident in the United Kingdom (and, accordingly, within the charge to corporation tax) at the beginning of the loss period.