Tax analysis: The First-tier Tax Tribunal upheld HMRC’s decision to deny an election for amortisation deductions on intangible fixed assets for the UK permanent establishments (PEs) of non-UK resident companies that had acquired additional partnership interests. The FTT found that the separate enterprise principle in Article 7 of the UK-US Double Tax Treaty DTT) did not require (or enable) looking through the partnership to the underlying intangible fixed assets.
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