Corporation Tax Act 2009 section 25

Non-UK resident banks: introduction

Section 25 introduces special rules for applying the separate enterprise principle to non-UK resident companies that are banks, while clarifying that similar principles can also apply to non-bank companies.

  • Sections 26 to 28 set out how the separate enterprise principle applies specifically to non-UK resident banks operating through a UK permanent establishment
  • The principles in those sections are not limited to banks โ€” similar approaches can apply when determining the chargeable profits of any non-UK resident company
  • The term "bank" is defined by reference to section 1120 of the Corporation Tax Act 2010
  • This section serves as an introductory gateway to the more detailed provisions that follow in sections 26 to 28

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