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Changes over time for: Section 127
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Status:
Point in time view as at 14/03/2012.
Changes to legislation:
Corporation Tax Act 2010, Section 127 is up to date with all changes known to be in force on or before 27 February 2025. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations.
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Changes to Legislation
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127Amounts excluded because of certain arrangementsU.K.
This section has no associated Explanatory Notes
(1)An amount (or part of an amount) resulting from Step 4 in section 113 is excluded if—
(a)it is not attributable for corporation tax purposes to any permanent establishment through which the surrendering company carries on a trade in the United Kingdom, and
(b)the following condition is met.
(2)The condition is that the amount (or part)—
(a)would not have resulted from Step 4 but for any arrangements within subsection (3), or
(b)would not have arisen to the surrendering company but for any such arrangements.
(3)Arrangements are within this subsection if their main purpose, or one of their main purposes, is to secure that the amount (or part) may be surrendered for the purposes of group relief.
(4)“Arrangements” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).
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