Sch 5 para 47
(1) This paragraph applies if— (a) before the commencement date a company incurs expenditure for the purposes of a UK property business it is about to carry on, (b) the company begins to carry on the business on or after the commencement date, and (c) when the company begins to carry on the business it is non-UK resident. (2) Subsection (7) of section 1147 of CTA 2009 (which enables a company to obtain relief for expenditure on contaminated or derelict land incurred prior to carrying on a UK property business) does not apply in relation to the expenditure.