Corporation Tax Act 2010

229 U.K. In section 39 (exclusion of expenditure by reference to tax on income) after subsection (4) insert—

“(5) If—

(a) because section 821(3) or (5) of CTA 2010 applies, the company charged to tax under Part 18 of that Act (transactions in land) is not the person (“B”) by whom the gain was realised, and

(b) the corporation tax has been paid,

for the purposes of this section the amount charged to that tax is regarded as having been charged as the income of B.”