Corporation Tax Act 2010 Explanatory Notes

Section 684: Disallowance of overseas property business losses

2124.This section restricts relief for the company’s overseas property business loss in cases in which this Chapter applies. It is based on section 768D of ICTA.

2125.Section 768D(9) of ICTA has to be read as implying that, in a case in which section 768D applies in relation to an overseas property business, references to section 392A of ICTA have to be read as references to the corresponding provisions of section 392B of ICTA. Otherwise section 768D of ICTA applies in such a case but does not actually do anything. This section therefore refers to section 66, which is based on section 392B of ICTA.

2126.Section 768D(5) of ICTA can have no application in relation to an overseas property business, and is therefore not rewritten in this section.

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