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Legislation
Corporation Tax Act 2009

Crossheading Anti-diversion rule

  • Section 18G Anti-diversion rule
  • Section 18H What are “diverted profits”?
  • Section 18HA Modification of Chapter 3 of Part 9A of TIOPA 2010
  • Section 18HB Modification of Chapter 4 of Part 9A of TIOPA 2010
  • Section 18HC Modification of Chapter 5 of Part 9A of TIOPA 2010
  • Section 18HD Modification of Chapter 7 of Part 9A of TIOPA 2010
  • Section 18HE Modification of Chapter 9 of Part 9A of TIOPA 2010
  • Section 18I Exemptions from anti-diversion rule
  • Section 18IA The excluded territories exemption
  • Section 18IB The low profits exemption
  • Section 18IC The low profit margin exemption
  • Section 18ID The tax exemption
  1. Anti-diversion rule
  2. Anti-diversion rule

Section 18G | Anti-diversion rule

From legislation.gov.uk

(1)This section applies for the purposes of this Chapter for any relevant accounting period (“period X”) of a company (“company X”) in relation to a territory outside the United Kingdom (“territory X”) if—

(a)there is an adjusted relevant profits amount in relation to territory X for period X,

(b)the adjusted relevant profits amount includes diverted profits (see section 18H), and

(c)none of the exemptions mentioned in section 18I applies for period X.

(2)The diverted profits are to be left out of the adjusted relevant profits amount.

(3)For the purposes of this Chapter “adjusted”, in relation to a relevant profits amount, is what the relevant profits amount would be if it were determined without reference to gains or losses which are chargeable gains or allowable losses for corporation tax purposes.

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