Part 4Loss relief
Chapter 2Trade losses
Other restrictions on relief
54Non-UK resident company: receipts of interest, dividends or royalties
1
This section applies if—
a
a non-UK resident company carries on a trade in the United Kingdom, and
b
tax-exempt receipts of interest, dividends or royalties arise to the company.
2
The receipts are not to be excluded from the profits of the trade so as to give rise to a loss to be deducted under any of these provisions—
a
section 37,
b
section 45, or
c
section 436A of ICTA.
3
For the purposes of subsection (1) a receipt is “tax-exempt” if it has been treated as tax-exempt under arrangements having effect under section 2 of TIOPA 2010.