Commentary

D4.801 Permanent establishment exemption

Corporate tax
Corporate tax | Commentary

D4.801 Permanent establishment exemption

Corporate tax | Commentary

Division D4.8     Double taxation relief—income and chargeable gains

For updates affecting this Division please see Part D0 Updates

Exempt overseas income

D4.801 Permanent establishment exemption

Companies can elect (on or after 19 July 2011) for the relevant profits/losses of a permanent establishment (PE) carried on outside the UK (a foreign permanent establishment) to be left out account when calculating the charge to UK corporation tax1. It is not possible to make this election in relation to profits of a trade of dealing in or developing UK land (B5.255)2. From 6 April 2019 it is not possible to make the election in

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