[259FA Circumstances in which the Chapter applies]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[Application of Chapter]

[259FA  Circumstances in which the Chapter applies]

[(1)     This Chapter applies if conditions A to C are met.

(2)     Condition A is that a company is a multinational company.

(3)     For the purposes of this Chapter, a company is a multinational company if—

(a)     it is resident in a territory outside the United Kingdom (“the parent jurisdiction”) for the purposes of a tax charged under the law of that territory, and

(b)     it is within the charge to corporation tax because it carries on a business in the United Kingdom through a permanent establishment in the United Kingdom.

(4)     Condition B is that, disregarding the provisions mentioned in subsection (5), there is an amount (“the PE deduction”) that—

(a)     may (in substance) be deducted from the company's income for the purposes of calculating the company's taxable profits for an accounting period (“the relevant PE period”) for corporation tax purposes, . . .

(b)     is in respect of a transfer of money or money's worth from the company in the United Kingdom

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