Corporation Tax Act 2009 section 206

Overseas property business

Section 206 defines what constitutes a company's overseas property business for corporation tax purposes.

• An overseas property business covers all business activities a company carries on to generate income from land situated outside the United Kingdom.
• It also includes any one-off transactions entered into for the purpose of generating income from overseas land, even if those transactions do not form part of an ongoing business.
• The definition mirrors that of a UK property business, with the sole difference being that the land in question is located outside the United Kingdom rather than within it.
• When determining whether an overseas property business exists, overseas land law concepts are interpreted in accordance with the rules set out in section 290 of the Act.