Commentary

D4.805 Quantification of income

Corporate tax
Corporate tax | Commentary

D4.805 Quantification of income

Corporate tax | Commentary

D4.805 Quantification of income

In addition to the rules at E6.434, the following specific provisions apply only to companies when establishing the amount of income on which credit relief is available (and assuming an election has not been made for exemption for the profits of a foreign permanent establishment (D4.801)).

UK company with overseas permanent establishment

The rules determining how the profits attributable to a PE for the purposes of tax credit relief are to be calculated were rewritten by FA 2011 as part of the changes which introduced the exempt branch income regime (D4.801). In practice there is not much difference between the pre and post FA 2011 rules. The pre FA 2011 rules referred to the provisions of CTA 2009, Pt 2 Ch 41; the post FA 2011 rules simply adopt and expand some of those provisions in order to clarify how the rules apply2.

The profits to be attributed to the PE are those profits of the company which

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