Commentary

D4.203 UK permanent establishments

Corporate tax
Corporate tax | Commentary

D4.203 UK permanent establishments

Corporate tax | Commentary

D4.203 UK permanent establishments

Where a non-UK resident company prepares its return of account for its UK permanent establishment in a non-sterling currency, the profits and losses of the permanent establishment that fall to be computed for corporation tax purposes in accordance with generally accepted accounting practice have first to be determined in that currency. The resulting profit or loss is then required to be translated into sterling using the appropriate exchange rate1. This is2:

  1.  

    (a)     the average rate for the period;

  2.  

    (b)     where the amount to be translated relates to a single transaction, an appropriate spot rate of exchange

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