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HMRC internal manual

International Manual

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HM Revenue & Customs
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UK residents with foreign income or gains: double taxation relief: Overseas branches

Before it was amended by FA 2011, TIOPA10/S43 applied the permanent establishment (PE) provisions of Chapter 4, Part 2 CTA 09 (previously ICTA88/S11AA) in determining for the purposes of S42(2) how much of a UK resident company’s chargeable profits was attributable to an overseas PE of the company. This replicated the treatment of UK branches of non-resident companies, including the attribution of capital (see INTM267120+), for overseas branches of UK companies for the purposes of calculating the UK measure of profits for DTR purposes

See INTM281000 for detail on the approach under TIOPA10/S43 as amended by FA 2011.