Corporation Tax Act 2009 section 1279

Exemption of profits from securities free of tax to residents abroad ("FOTRA securities")

Section 1279 provides an exemption from corporation tax for profits arising from FOTRA securities, subject to two conditions being satisfied and timely repayment claims.

• Profits from FOTRA securities or related loan relationships are exempt from corporation tax when two conditions are met
• Condition A requires that the profits are stated in the exemption condition as being exempt from corporation tax
• Condition B requires that any requirements for obtaining the exemption, as set out in the security's conditions of issue, are fulfilled
• The exemption does not extend the time limit for claiming a repayment of tax — any such claim must still be made within the normal deadline