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HMRC internal manual

Company Taxation Manual

Groups: group relief: overseas permanent establishment of UK resident company - foreign ‘tie-breaker’ rules

CTA10/Ss106(6) and (7)

For guidance about tax relief in a foreign jurisdiction for the purposes of CTA10/S106 see CTM80360.

Sometimes the rules of a foreign jurisdiction turn on whether a loss or other amount of a surrendering company, or an equivalent amount, is deductible for tax purposes in the UK. In such a case the loss or other amount is only treated as deductible in the foreign jurisdiction if that jurisdiction treats the surrendering company as a resident for tax purposes.