Introduction Equity holders Overview Section 186: When activities of a company are double taxation exempt
737.This section explains what is meant by activities that are double taxation exempt. It is based on section 403D of, and paragraph 5F of Schedule 18 to, ICTA.
738.The definition is used in sections 107(4), 108(3), 140(8), and 182(b).
739.Subsection (1) makes the link between the activities that are described in the Part as exempt and the profits from those activities which are the subject of exemption under a DTA.
740.Subsection (2) makes clear that activities are to be treated as exempt whether or not any necessary claim for exemption is actually made.
741.Subsection (3) defines “double taxation arrangements” by reference tosection 2 of TIOPA. They are “… arrangements … made in relation to any territory outside the United Kingdom with a view to affording relief from double taxation in relation to …” the taxes within subsection (3) of that section.