Related Commentary  Related HMRC Manuals

356OE(1)  The relevant amount is to be treated for corporation tax purposes as profits of a trade carried on by the chargeable company.

356OE(2)  If the chargeable company is non-UK resident, that trade is the company’s trade of dealing in or developing UK land.

356OE(3)  But subsection (1) does not apply to an amount so far as it would (apart from this section) be brought into account as income in calculating profits (of any person)–

(a)for corporation tax purposes, or

(b)for income tax purposes.

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