Corporation Tax Act 2010 section 181

Assumptions to be applied if non-UK resident company involved

Section 181 sets out four assumptions that must be applied when calculating the "alternative proportion" under section 180, where a non-UK resident company is involved in determining equity holder entitlements for group relief purposes.

• Distributions of profits or assets are restricted to those referable to the non-UK resident company's UK trade only, not its worldwide operations
• When testing profit entitlements, total profits are capped at the amount referable to the company's UK trade
• When testing asset entitlements on a notional winding up, assets and liabilities are similarly capped at those referable to the UK trade
• No ordinary equity holder is treated as having a beneficial entitlement to UK trade profits or assets greater than the proportion they would receive if these UK-only restrictions were ignored