Income and Corporation Taxes Act 1988 (c. 1)

SCHEDULES

SCHEDULE A1 U.K. Determination of profits attributable to permanent establishment: supplementary provisions

Part 3 U.K. Provisions applicable to non-resident banks

Non-resident banks: transfer of financial assets U.K.

8 (1) In accordance with the separate enterprise principle, transfers of loans and other financial assets between the permanent establishment and any other part of the company are recognised only if they would have taken place between independent enterprises.

(2) Such a transfer is not recognised where it cannot reasonably be considered that it is carried out for valid commercial reasons. For this purpose the obtaining of a tax advantage is not a valid commercial reason.