[259HA Circumstances in which the Chapter applies]

[Application of Chapter]

[259HA  Circumstances in which the Chapter applies]

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

(2)     Condition A is that a payment or quasi-payment is made under, or in connection with, an arrangement.

(3)     Condition B is that a payee is a multinational company.

(4)     For the purposes of this Chapter, a company is a “multinational company” if—

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

(b)     it is regarded as carrying on a business in another territory (“the PE jurisdiction”) through

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