s 182 Assets etc referable to UK trade
Profits, assets or liabilities of company B are referable to company B's UK trade so far as they— (a) are attributable to, or used for the purposes of, activities the income or chargeable gains from which are or (if there were any) would be brought into account in calculating company B's total profits of any accounting period, and (b) are not attributable to, or used for the purposes of, activities which are double taxation exempt for any accounting period (see section 186).