Commentary on Sections Part 2: Charge to corporation tax: basic provisions Overview Section 25: Non-UK resident banks: introduction
130.This section introduces sections 26 to 28 which contain particular provisions applying the separate enterprise principle to banks. It is based on paragraph 7(1) and (2) of Schedule A1 to ICTA.
131.While these provisions are an application of the separate enterprise principle with particular relevance to banks, the principles behind them are applicable to companies other than banks and subsection (2) clarifies this point.