SCHEDULES

F1F1F2SCHEDULE A1Determination of profits attributable to permanent establishment: supplementary provisions

Annotations:
Amendments (Textual)
F1

Sch. A1 repealed (1.4.2009 with effect in accordance with s. 1329(1) of the repealing Act) by Corporation Tax Act 2009 (c. 4), Sch. 1 para. 278, Sch. 3 Pt. 1 (with Sch. 2 Pts. 1, 2)

F2

Sch. A1 inserted (with effect in accordance with s. 149(6) of the amending Act) by Finance Act 2003 (c. 14), s. 149(3), Sch. 25

Part 2General provisions

Provision of goods or services for permanent establishment

6

1

This paragraph applies where the non-resident company provides the permanent establishment with goods or services.

2

If the goods or services are of a kind that the company supplies, in the ordinary course of its business, to third parties dealing with it at arm’s length, the matter is dealt with as a transaction to which the separate enterprise principle applies.

3

If not, the matter is dealt with as an expense incurred by the non-resident company for the purposes of the permanent establishment.