Corporation Tax Act 2009 (c. 4)

Part 16 U.K. Companies with investment business

Chapter 2 U.K. Management expenses

Relief for expenses of management U.K.

1222 Income from a source not charged to tax U.K.

(1) This section applies to a UK resident company if—

(a) income arises to the company from a source not charged to tax,

(b) the company has the source in the course of carrying on its investment business, and

(c) the income is not franked investment income.

(2) This section applies to a non-UK resident company if—

(a) income arises to the company from a source not charged to tax,

(b) the company has the source in the course of carrying on its investment business through a permanent establishment in the United Kingdom,

(c) the source is property or rights used by, or held by or for, that establishment, and

(d) the income is not franked investment income.

(3) The amount of that income is deducted from the amount (if any) that would otherwise be deductible under section 1219 for the accounting period in which the income arises.