Commentary

D4.723 Dual territory double deduction cases

Corporate tax
Corporate tax | Commentary

D4.723 Dual territory double deduction cases

Corporate tax | Commentary

D4.723 Dual territory double deduction cases

There are two conditions which must both be met for the rules restricting a double deduction to apply, as follows1:

  1.  

    (a)     a company is either a dual resident company, or a relevant multinational company. A dual resident company is one which is both resident in the UK and another territory. A relevant multinational company is one which is subject to tax under the law of a territory outside its territory of residence, by reason of carrying on a business through a PE there ('the PE jurisdiction') and the UK is either the PE jurisdiction or the territory of residence ('the parent jurisdiction');

  2.  

    (b)     there is an amount which, it is reasonable to suppose could, by reason of the company being a dual resident company or relevant multinational company, be deducted from the income of the company for an accounting period for corporation tax

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