Related Commentary  Related HMRC Manuals

167(1)  Subsections (2) and (3) set out exceptions to section 166(1).

167(2)  The first exception is if the small or medium-sized enterprise elects for section 166(1) not to apply in relation to the chargeable period.

Any such election is irrevocable.

167(3)  The second exception is if–

(a)the other affected person, or

(b)a party to a relevant transaction,

is, at the time when the actual provision is or was made or imposed, a resident of a non-qualifying territory (whether or not that person is also a resident of a qualifying territory).

167(4)  For the purposes of subsection (3)–

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