Version Superseded: 10/06/2021
Point in time view as at 07/04/2005. This version of this provision has been superseded.
There are currently no known outstanding effects for the Income Tax (Trading and Other Income) Act 2005, Section 759.
(1)This section supplements condition A in section 758.
(2)It applies in a case where a company is resident in one territory and has a permanent establishment in another territory.
(3)The permanent establishment (and not the company) is to be treated as the person making the payment so far as (within the meaning of Article 1(3) of the Directive) the payment represents a tax-deductible expense for the permanent establishment in the territory in which it is situated.
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