SCHEDULES

SCHEDULE 24U.K.M1ASSUMPTIONS FOR CALCULATING CHARGEABLE PROFITS, CREDITABLE TAX AND CORRESPONDING UNITED KINGDOM TAX OF FOREIGN COMPANIES

Modifications etc. (not altering text)

Marginal Citations

M1Source-1984 Sch. 16, 1985 Sch. 14 16

Company reconstructionsU.K.

8U.K.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).

Textual Amendments

F1Words in Sch. 24 para. 8 substituted (1.4.2010 with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), Sch. 1 para. 146(3)(a) (with Sch. 2)

F2Words in Sch. 24 para. 8 substituted (1.4.2010 with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), Sch. 1 para. 146(3)(b) (with Sch. 2)

F3Words in Sch. 24 para. 8(b) substituted (with effect in accordance with s. 153(4) of the amending Act) by Finance Act 2003 (c. 14), s. 153(1)(a)