2A

But the company’s “chargeable profits” do not include—

a

profits of a trade of dealing in or developing UK land (see section 5B),

b

profits of a UK property business,

c

profits consisting of other UK property income, or

d

profits arising from loan relationships or derivative contracts that the company is a party to for the purposes of its UK property business or for the purposes of enabling it to generate other UK property income.