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HMRC internal manual

International Manual

Double Taxation applications and claims: Applicants/claimants: Claims by financial concerns under Business Profits Article: Requests to extend the provisions to other income

If the claimant asks you to extend the concession to dividends or other distributions you should ask the HMRC office for the permanent establishment (PE) to confirm that

  • the payments represent trading income


  • they are not attributable to the PE.

The reason for doing this is because dividends/distributions, unlike interest and royalties, cannot be brought into the charge to corporation tax on the PE (CTA09/S19).