Corporation Tax Act 2010 section 123

Assumptions as to UK residence

Section 123 establishes the first of four sets of assumptions that must be applied when recalculating the EEA amount using United Kingdom tax rules, specifically requiring the surrendering company to be treated as if it were UK resident.

• When recalculating the EEA amount, you must assume that the surrendering company is resident in the United Kingdom.
• This assumption of UK residence does not change where the company's activities are actually carried on — that is dealt with separately under section 124.
• The assumption does not treat the company as ceasing to be UK resident at the end of the EEA accounting period, although section 125 separately treats the company's accounting period as ending at that point.
• The surrendering company is assumed to become UK resident at the beginning of the EEA accounting period.