Part 5Group relief
Chapter 2Surrender of company’s losses etc for an accounting period
Restrictions on losses and other amounts that may be surrendered
108Meaning of “non-UK profits”
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.