Corporation Tax Act 2010 section 182

Assets etc. referable to UK trade

Section 182 determines the extent to which a company's profits, assets or liabilities are treated as referable to its UK trade for the purposes of group relief.

• Profits, assets or liabilities are referable to a company's UK trade if they relate to activities whose income or gains count towards the company's total taxable profits.
• Even if there are currently no income or gains, the test still applies if there would be amounts brought into account if any arose.
• Amounts connected to activities that are exempt from UK tax under a double taxation agreement are excluded, even if those activities would otherwise qualify.
• The definition of "double taxation exempt" activities is set out separately in section 186.