27 Loans: attribution of financial assets and profits arising

27  Loans: attribution of financial assets and profits arising

(1)     This section applies if the non-UK resident company—

(a)     is a bank, and

(b)     makes a loan or has another financial asset.

(2)     In accordance with the separate enterprise principle, the loan or other financial asset, and profits arising from it, are attributed to the permanent establishment so far

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