Corporation Tax Act 2009 section 18K

Total opening negative amount: "matching"

Section 18K explains how the total opening negative amount (representing cumulative past losses of foreign permanent establishments at the point of electing for exemption) is matched against subsequent profits, and how this affects the availability of the foreign PE profits exemption.

Access full legislation.And much more.

By becoming a member, your team gets full access to Tax World research tools and source-backed tax resources.