Section 1222 — Corporation Tax Act 2009: Income from a source not charged to tax

Income from a source not charged to tax 1222 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 does not consist of exempt ABGH distributions.

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 does not consist of exempt ABGH distributions.

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.

4 In this section “ exempt ABGH distribution ” means a distribution which—

a is a distribution for the purposes of the Corporation Tax Acts only because it falls within paragraph A, B, G or H in section 1000(1) of CTA 2010, and b is exempt for the purposes of Part 9A (company distributions).