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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.