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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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Non-residents trading in the UK: profits of the PE: contents

  1. INTM267010
    Introduction to attribution
  2. INTM267020
    Construction of the domestic charge to tax on non-residents
  3. INTM267030
    Domestic provisions on quantifying chargeable profits - Income Tax and Corporation Tax
  4. INTM267040
    The separate entity principle and use of transfer pricing methodology
  5. INTM267050
    Attribution - method of calculation of chargeable profits
  6. INTM267060
    Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Comparable Uncontrolled Price
  7. INTM267070
    Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Resale Method
  8. INTM267080
    Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Cost Plus
  9. INTM267090
    Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Profit Split Method
  10. INTM267100
    Allocation of expenses in the attribution exercise
  11. INTM267110
    Interest receivable by PE
  12. INTM267120
    Attribution of capital to the permanent establishment - companies only: FA2003 domestic legislation - an overview
  13. INTM267130
    Attribution of capital to the permanent establishment - companies only: practical 4 step approach
  14. INTM267140
    Attribution of capital to the permanent establishment - companies only: alternative approaches to calculating the capital attribution tax adjustment
  15. INTM267150
    Attribution of capital to the permanent establishment - companies only: practical example - non-financial business
  16. INTM267160
    Treaty provisions - Article 7 (business profits article) - interaction with domestic provisions
  17. INTM267170
    PE capital gains chargeable on the non-resident
  18. INTM267180
    Non-residents trading in the UK: overseas permanent establishments of UK resident companies: overview
  19. INTM267190
    Non-residents trading in the UK: overseas permanent establishments of UK resident companies: the capital attribution approach
  20. INTM267200
    Non-residents trading in the UK: overseas permanent establishments of UK resident companies: approach to capital attribution in the host state
  21. INTM267500
    UK subsidiaries of foreign banks and foreign banks trading in the UK through permanent establishments: contents