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HMRC internal manual

International Manual

The attribution of capital to foreign banking permanent establishments in the UK: Application to permanent establishments of UK companies

Overseas permanent establishments of UK companies

Before it was amended by FA 2011, TIOPA10/S43 applied the permanent establishment (PE) provisions of Chapter 4, Part 2 CTA09 (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.

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