SCHEDULES
C1SCHEDULE 24M1ASSUMPTIONS FOR CALCULATING CHARGEABLE PROFITS, CREDITABLE TAX AND CORRESPONDING UNITED KINGDOM TAX OF FOREIGN COMPANIES
Source-1984 Sch. 16, 1985 Sch. 14 16
Company reconstructions
8
Without prejudice to the operation of F1Chapter 1 of Part 22 of CTA 2010 in a case where the company is the predecessor, within the meaning of F2that Chapter, and a company resident in the United Kingdom is the successor, within the meaning of F2that Chapter—
a
the assumption that the company is resident in the United Kingdom shall not be regarded as requiring it also to be assumed that the company is within the charge to tax in respect of a trade for the purposes of F2that Chapter, and
b
except in so far as the company is actually within that charge (by carrying on the trade through a F3permanent establishment in the United Kingdom), it shall accordingly be assumed that the company can never be the successor, within the meaning of F2that Chapter, to another company (whether resident in the United Kingdom or not).
Sch. 24 modified (28.7.2000) by Finance Act 2000 (c. 17), Sch. 22 para. 54(2)-(5)