Corporation Tax Act 2010 section 186

When activities of a company are double taxation exempt

Section 186 defines what it means for a company's activities to be "double taxation exempt" for an accounting period, and clarifies how this status is determined.

• Activities are double taxation exempt if, under a double taxation agreement, the income and chargeable gains from those activities are excluded when calculating the company's chargeable profits for the period.
• When assessing whether activities qualify as double taxation exempt, it is assumed that any claim required to activate the relevant provisions of the double taxation agreement has been made, regardless of whether it actually has.
• "Double taxation arrangements" means agreements given effect under section 2(1) of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010), which provides relief from double taxation through treaties with territories outside the United Kingdom.
• This definition is relevant to several other provisions in the same Part of the Act, including sections 107(4), 108(3), 140(8), and 182(b).