Corporation Tax Act 2010 section 1144

Alternative finance arrangements

Section 1144 protects non-UK resident companies receiving alternative finance return from being treated as having a UK permanent establishment solely because of the alternative finance arrangements.

• A non-UK resident company receiving alternative finance return will not be regarded as having a UK permanent establishment merely because of activities carried out in connection with the alternative finance arrangements.
• This protection applies to actions taken by the counterparty to the arrangements or by any other person acting on behalf of the non-UK resident company in relation to those arrangements.
• Alternative finance return covers returns arising under purchase and resale arrangements, diminishing shared ownership arrangements, and other specified alternative finance structures as defined in the Income Tax Act 2007 and the Corporation Tax Act 2009.
• The section ensures that Sharia-compliant and other alternative finance products do not inadvertently create a taxable UK presence for overseas companies.