Commentary

A4.452 Permanent establishments

Administration and compliance

A4.452 Permanent establishments

A4.452 Permanent establishments

Where a payment of interest or royalties is made by a permanent establishment in one territory (A) of a company resident in a different territory (B), the payment is treated as made by the permanent establishment in A (and not by the company in B) to the extent that it is a tax-allowable expense of the permanent establishment in A1. This rule determines whether Condition A in A4.451 is fulfilled in such circumstances.

Where a receipt of interest or royalties is effectively connected with a UK permanent establishment or a non-EU permanent establishment of an EU company, that

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