Finance Act 2015

89Section 86: calculation of profits where only tax avoidance condition is met

This section has no associated Explanatory Notes

(1)This section applies where—

(a)section 86 applies for an accounting period, and

(b)the mismatch condition is not met.

(2)The taxable diverted profits that arise to the foreign company in the accounting period by reason of that section applying are an amount equal to the notional PE profits for that period.