Corporation Tax Act 2010 section 521

"UK company" and "non-UK company"

Section 521 defines what is meant by "UK company" and "non-UK company" for the purposes of the tax-exempt distributions rules in this Part of the Act.

• A "UK company" must be UK resident and must not also be resident in another jurisdiction under that jurisdiction's tax laws.
• This definition is narrower than "UK resident company" — a company that is dual-resident does not qualify as a "UK company."
• A "non-UK company" is simply any company that does not meet the "UK company" definition.
• Within a group of companies, references to "UK member" or "non-UK member" follow the same definitions.