SCHEDULES
SCHEDULE A1Determination of profits attributable to permanent establishment: supplementary provisions
Part 3Provisions applicable to non-resident banks
Non-resident banks: transfer of financial assets
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(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.