Commentary

D4.713 Permanent establishment deduction / non-inclusion arrangements—counteraction

Corporate tax
Corporate tax | Commentary

D4.713 Permanent establishment deduction / non-inclusion arrangements—counteraction

Corporate tax | Commentary

D4.713 Permanent establishment deduction / non-inclusion arrangements—counteraction

The rules provide for counteraction by restricting the deduction available on an excessive (D4.710) permanent establishment deduction. The excessive permanent establishment deduction can only be deducted from 'dual inclusion income' for the period1. Dual inclusion income is income which is taxable income in both the permanent establishment jurisdiction and, for a permitted taxable period, the parent company jurisdiction2. A company's taxable period is permitted for these purposes if it begins before the end of 12 months after the accounting period ends or if it begins later and a claim has been made for

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