Test your understanding: answers
(1). The conditions that must be satisfied in order for the loss of the overseas permanent establishment to be offset against the income and gains of RCO Ltd are:
- RCO Ltd must not have elected to exclude the profits and losses of its overseas permanent establishments from UK corporation tax, and
- the permanent establishment must be controlled from the UK.
(2). Statement A is false.
The election to exclude the profits and losses of overseas permanent establishments applies to all of a company’s existing and future overseas permanent establishments.
Statement B is true.
