Corporation Tax Act 2010 Explanatory Notes

Section 1148: Section 1147: interpretation

3272.This section defines three terms used in section 1147. It is based on paragraph 4(2) to (4) of Schedule 26 to FA 2003.

3273.Subsection (2) makes explicit that the accounting periods referred to in paragraph 4(2) of Schedule 26 to FA 2003 are those of the non-UK resident company.

3274.Subsection (3) adopts the term “relevant disregarded income” in preference to the term “relevant excluded income” in paragraph 4(3) of Schedule 26 to FA 2003. Section 821 of ITA, which is also based on paragraph 4(3) of Schedule 26 to FA 2003, similarly adopts the term “relevant disregarded income”.

3275.In subsection (3), a reference to “the total of the non-UK resident company’s income” has been substituted for the reference in paragraph 4(3) of Schedule 26 to FA 2003 to “the aggregate of such of the chargeable profits of the company”. See Change 62 in Annex 1.

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