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Corporation Tax Act 2010

Section 124: Assumptions as to places in which activities carried on

462.This section is the second of four sets of assumptions to be made in recalculating the EEA amount using United Kingdom tax rules.It is based on paragraph 13 of Schedule 18A to ICTA.

463.Subsection (1) requires the assumption that the company’s activities are carried on in the United Kingdom instead of in the EEA territory. So any special rules about foreign income do not apply.

464.Subsection (2) makes clear that the assumption in subsection (1) includes the assumption that any land held by the surrendering company is in the United Kingdom.

465.Subsection (3) explains how the United Kingdom concepts of law in subsection (2) (“estate”, “interest” and “rights”) are to be applied to land that is outside the United Kingdom.

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