Section 108 — Corporation Tax Act 2010: Meaning of “non-UK profits”

Meaning of “non-UK profits” 108 1 In sections 106 and 107 “ non-UK profits ”, in relation to a person, means—

a amounts within subsection (2), or b amounts taken into account in calculating amounts within subsection (2).

2 Amounts are within this subsection if they—

a are taken for the purposes of the non-UK tax in question to be the amount of the profits, income or gains on which (after allowing for deductions) the person is charged with that tax, and b are not amounts corresponding to, and are not represented in, the total profits of any person of any accounting period.

3 For the purposes of subsection (2)(b) amounts that arise from activities of a non-UK resident company that are double taxation exempt for an accounting period (see section 186) are excluded from the company's total profits of that period.