Section 1222 | Income from a source not charged to tax

(1)This section applies to a UK resident company if—

(a)income arises to the company from a source not charged to tax,

(b)the company has the source in the course of carrying on its investment business, and

(c)the income does not consist of exempt ABGH distributions.

(2)This section applies to a non-UK resident company if—

(a)income arises to the company from a source not charged to tax,

(b)the company has the source in the course of carrying on its investment business through a permanent establishment in the United Kingdom,

(c)the source is property or rights used by, or held by or for, that establishment, and

(d)the income does not consist of exempt ABGH distributions.

(3)The amount of that income is deducted from the amount (if any) that would otherwise be deductible under section 1219 for the accounting period in which the income arises.

(4)In this section “exempt ABGH distribution” means a distribution which—

(a)is a distribution for the purposes of the Corporation Tax Acts only because it falls within paragraph A, B, G or H in section 1000(1) of CTA 2010, and

(b)is exempt for the purposes of Part 9A (company distributions).