Commentary

D4.716 Multinational payee deduction/non-inclusion arrangements—counteraction

Corporate tax
Corporate tax | Commentary

D4.716 Multinational payee deduction/non-inclusion arrangements—counteraction

Corporate tax | Commentary

D4.716 Multinational payee deduction/non-inclusion arrangements—counteraction

The primary counteraction where the UK is the payer jurisdiction, is to deny a deduction for the multinational payee mismatch amount or, for payments after 1 January 2020 where the multinational company is UK resident for the payment period and is regarded as carrying on a business through a permanent establishment in the permanent establishment territory under the law of the parent jurisdiction but is not so regarded under the law of the permanent establishment jurisdiction (ie paragraph b of Condition C in TIOPA 2010, s 259HA(5) is met), to treat that amount as income

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial