SCHEDULES

SCHEDULE 13Profits of foreign permanent establishments etc

Part 1Amendments of CTA 2009

5

In section 775(4) (intangible fixed assets: cases where transfers within group provisions do not apply), omit the “or” at the end of paragraph (a) and insert at the end“, or

(c)

an election under section 18A has effect in relation to the transferor and the asset has at any time been held by the transferor wholly or partly for the purposes of a permanent establishment in a territory outside the United Kingdom through which the transferor carries on business.”