Section 431A | Foreign permanent establishment exemption ^F1

(1)Subsection (2) applies if—

(a)an election under section 18A of CTA 2009 has effect in relation to a company, and

(b)the company carries on any trade which consists of, or includes, the working of a source of mineral deposits.

(2)That trade so far as carried on through one or more permanent establishments outside the United Kingdom is treated for the purposes of this Part as a trade—

(a)separate from any other trade of the company, and

(b)all the profits and gains from which are not, or (if there were any) would not be, chargeable to tax.