Section 54 | Non-UK resident company: receipts of interest, dividends or royalties
From legislation.gov.uk
(1)This section applies if—
(a)a non-UK resident company carries on a trade in the United Kingdom, and
(b)tax-exempt receipts of interest, dividends or royalties arise to the company.
(2)The receipts are not to be excluded from the profits of the trade so as to give rise to a loss to be deducted under section 37 , 45, 45A or 45B .
(3)For the purposes of subsection (1) a receipt is “tax-exempt” if it has been treated as tax-exempt under arrangements having effect under section 2 of TIOPA 2010.