[259KB Meaning of “dual territory double deduction”, “excessive PE deduction” and “PE jurisdiction”]
Taxation (International and Other Provisions) Act 2010 (2010 c 8) | Legislation

[259KB  Meaning of “dual territory double deduction”, “excessive PE deduction” and “PE jurisdiction”]

[(1)     This section has effect for the purposes of this Chapter.

(2)     A “dual territory double deduction” means an amount that can be deducted by a company both—

(a)     from income for the purposes of a tax charged under the law of one territory, and

(b)     from income for the purposes of a tax charged under the law of another territory.

(3)     A “PE deduction” is an amount that—

(a)     may (in substance) be deducted from a company's income for the purposes of calculating the company's taxable profits, for a taxable period, for the purposes of a tax that is charged on the company,

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