Part 2Double taxation relief
CHAPTER 2Double taxation relief by way of credit
Unrelieved foreign tax on profits of overseas permanent establishment
78Meaning of “overseas permanent establishment”
(1)
For the purposes of sections 72 to 76 “overseas permanent establishment” means a permanent establishment through which the company carries on a trade in a territory outside the United Kingdom.
(2)
In subsection (1) “permanent establishment”—
(a)
if the arrangements are double taxation arrangements and define the expression, has the meaning given by the arrangements, and
(b)
if the arrangements are double taxation arrangements but do not define the expression, or if the arrangements are unilateral relief arrangements for a territory outside the United Kingdom, is to be read in accordance with Chapter 2 of Part 24 of CTA 2010.