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INTM267000 | Non-residents trading in the UK: profits of the PE: contents

From HM Revenue & Customs · International Manual

Contents21 entries

  1. INTM267010Non-residents trading in the UK: profits of the PE: Introduction to attribution
  2. INTM267020Non-residents trading in the UK: profits of the PE: Construction of the domestic charge to tax on non-residents
  3. INTM267030Non-residents trading in the UK: profits of the PE: Domestic provisions on quantifying chargeable profits - Income Tax and Corporation Tax
  4. INTM267040Non-residents trading in the UK: profits of the PE: The separate entity principle and use of transfer pricing methodology
  5. INTM267050Non-residents trading in the UK: profits of the PE: Attribution - method of calculation of chargeable profits
  6. INTM267060Non-residents trading in the UK: profits of the PE: Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Comparable Uncontrolled Price
  7. INTM267070Non-residents trading in the UK: profits of the PE: Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Resale Method
  8. INTM267080Non-residents trading in the UK: profits of the PE: Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Cost Plus
  9. INTM267090Non-residents trading in the UK: profits of the PE: Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Profit Split Method
  10. INTM267100Non-residents trading in the UK: profits of the PE: Allocation of expenses in the attribution exercise
  11. INTM267110Non-residents trading in the UK: profits of the PE: Interest receivable by PE
  12. INTM267120Non-residents trading in the UK: profits of the PE: Attribution of capital to the permanent establishment - companies only: FA2003 domestic legislation - an overview
  13. INTM267130Non-residents trading in the UK: profits of the PE: Attribution of capital to the permanent establishment - companies only: practical 4 step approach
  14. INTM267140Non-residents trading in the UK: profits of the PE: Attribution of capital to the permanent establishment - companies only: alternative approaches to calculating the capital attribution tax adjustment
  15. INTM267150Non-residents trading in the UK: profits of the PE: Attribution of capital to the permanent establishment - companies only: practical example - non-financial business
  16. INTM267160Non-residents trading in the UK: profits of the PE: Treaty provisions: Article 7 (business profits article) - interaction with domestic provisions
  17. INTM267170Non-residents trading in the UK: profits of the PE: PE capital gains chargeable on the non-resident
  18. INTM267180Non-residents trading in the UK: overseas permanent establishments of UK resident companies: overview
  19. INTM267190Non-residents trading in the UK: overseas permanent establishments of UK resident companies: the capital attribution approach
  20. INTM267200Non-residents trading in the UK: overseas permanent establishments of UK resident companies: approach to capital attribution in the host state
  21. INTM267500UK subsidiaries of foreign banks and foreign banks trading in the UK through permanent establishments