Taxation (International and Other Provisions) Act 2010 (c. 8)

Part 2 Double taxation relief

CHAPTER 2 Double taxation relief by way of credit

Limit on credit against corporation tax

43 Profits attributable to permanent establishment for purposes of section 42(2)

(1) The permanent-establishment provisions apply with the necessary modifications in determining for the purposes of section 42(2) how much of a UK resident company’s chargeable profits is attributable to a permanent establishment of the company outside the United Kingdom.

(2) In subsection (1)—

• “chargeable profits” means profits on which corporation tax is chargeable, and

• “the permanent-establishment provisions” means—

  (a)

  Chapter 4 of Part 2 of CTA 2009 (profits attributable to permanent establishment), and

  (b)

  any regulations made under section 24 of CTA 2009 (application to insurance companies).