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Corporation Tax Act 2010

International

338.In the simplest case, all the companies involved are resident in the United Kingdom and carry on their businesses wholly in the United Kingdom. But the relief is extended to includethe losses of:

  • some companies not resident in the United Kingdom that carry on a trade through a permanent establishment in the United Kingdom; and

  • some companies resident in the EEA (or carrying on a trade through a permanent establishment there).

339.And the relief is restricted in some cases if a UK resident company’s business is not carried on wholly in the United Kingdom.

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