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

[259JE  Meaning of excessive PE inclusion income]

[(1)     In section 259JD(10), “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 a company for an accounting period 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

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