Corporation Tax Act 2009 section 18CA

Income arising from immovable property

Section 18CA clarifies that income from immovable property (such as land and buildings) used in the business of a foreign permanent establishment can form part of the profits or losses attributable to that establishment for the purposes of the foreign PE exemption.

• Income from immovable property used for the business of a foreign permanent establishment counts as profit attributable to that PE
• The amount included is proportionate to the extent the property has actually been used for the PE's business
• This treatment applies equally to losses, not just profits
• The provision supports the broader foreign PE exemption rules under section 18A