- UK-resident companies will be required to exclude profits and losses attributable to foreign permanent establishments from their corporation tax computation, effectively making the existing elective foreign branch exemption mandatory.
- Existing transitional rules will be amended in relation to relieving current-regime tax losses and other attributes against UK profits that arise after the effective date.
- Draft legislation has been published for technical consultation.
- Timing: the new rules would apply for corporation tax accounting periods beginning on or after 1 January 2027. The consultation closed on 13 September 2026.
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