[259FC Meaning of excessive PE inclusion income]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[259FC  Meaning of excessive PE inclusion income]

[(1)     In section 259FB(5), “excessive PE inclusion income” of the company means—

(a)     where paragraph (a) of subsection (4) applies, the PE inclusion income of the company, or

(b)     where paragraph (b) of that subsection applies, the PE inclusion income of the company so far as it is reasonable to suppose that it exceeds the aggregate effect on taxable profits.

(2)     For this purpose, “PE inclusion income” of the company means an amount in respect of which conditions A and B are met.

(3)     Condition A is that the amount is in respect of a transfer of money or money's worth

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