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INTM286000 | Foreign Permanent Establishments of UK Companies: anti-diversion rule for relevant periods beginning before 1 January 2013 and the anti-diversion rule for relevant accounting periods beginning on or after 1 January 2013: contents

From HM Revenue & Customs · International Manual

Contents33 entries

  1. INTM286010Foreign Permanent Establishments of UK Companies: anti-diversion rule: introduction
  2. INTM286020Foreign Permanent Establishments of UK Companies: anti-diversion rule: lower level of tax test
  3. INTM286030Foreign Permanent Establishments of UK Companies: anti-diversion rule: motive test
  4. INTM286040Foreign Permanent Establishments of UK Companies: anti-diversion rule: motive test: condition A
  5. INTM286050Foreign Permanent Establishments of UK Companies: anti-diversion rule: motive test: condition B
  6. INTM286060Foreign Permanent Establishments of UK Companies: anti-diversion rule: proportionate reduction where motive test not met
  7. INTM286070Foreign Permanent Establishments of UK Companies: anti-diversion rule: transitional provisions
  8. INTM286080Foreign Permanent Establishments of UK Companies: anti-diversion rule: safe harbour provisions
  9. INTM286090Foreign Permanent Establishments of UK Companies: anti-diversion rule: cases where safe harbour provisions not met
  10. INTM286100Foreign Permanent Establishments of UK Companies: anti-diversion rule: “Period of Grace” clearances
  11. INTM286110Foreign Permanent Establishments of UK Companies: anti-diversion rule: proportionate reduction where tainted relevant transactions arise
  12. INTM286300Foreign Permanent Establishments of UK Companies: anti-diversion rule: Introduction for relevant accounting periods beginning on or after 1 January 2013.
  13. INTM286310Foreign Permanent Establishments of UK Companies: anti-diversion rule: When does it apply?
  14. INTM286320Foreign Permanent Establishments of UK Companies: anti-diversion rule: Diverted Profits Gateway Approach
  15. INTM286330Foreign Permanent Establishments of UK Companies: anti-diversion rule: Application of the Diverted Profits Gateway
  16. INTM286340Foreign Permanent Establishments of UK Companies: anti-diversion rule: Initial gateway filter - Chapter 3
  17. INTM286350Foreign Permanent Establishments of UK Companies: anti-diversion rule: Initial gateway filter - Does Chapter 4 apply?
  18. INTM286360Foreign Permanent Establishments of UK Companies: anti-diversion rule: Initial gateway filter - Does Chapter 5 apply?
  19. INTM286370Foreign Permanent Establishments of UK Companies: anti-diversion rule: Initial gateway filter - Does Chapter 6 apply?
  20. INTM286380Foreign Permanent Establishments of UK Companies: anti-diversion rule: Initial gateway filter - Does Chapter 7 apply?
  21. INTM286390Foreign Permanent Establishments of UK Companies: anti-diversion rule: Chapter 4.
  22. INTM286400Foreign Permanent Establishments of UK Companies: anti-diversion rule: Chapters 5 and 9.
  23. INTM286410Foreign Permanent Establishments of UK Companies: anti-diversion rule: Chapter 6.
  24. INTM286420Foreign Permanent Establishments of UK Companies: anti-diversion rule: Chapter 7.
  25. INTM286430Foreign Permanent Establishments of UK Companies: anti-diversion rule: Diverted Profits Gateway Approach: Example 1.
  26. INTM286440Foreign Permanent Establishments of UK Companies: anti-diversion rule: Diverted Profits Gateway Approach: Example 2.
  27. INTM286450Foreign Permanent Establishments of UK Companies: anti-diversion rule: Diverted Profits Gateway Approach: Example 3.
  28. INTM286460Foreign Permanent Establishments of UK Companies: anti-diversion rule: Entity Exemption Approach
  29. INTM286470Foreign Permanent Establishments of UK Companies: anti-diversion rule: Application of the entity exemption approach
  30. INTM286480Foreign Permanent Establishments of UK Companies: anti-diversion rule: Chapter 11 - Excluded Territories Exemption
  31. INTM286490Foreign Permanent Establishments of UK Companies: anti-diversion rule: Chapter 12 - Low Profits Exemption
  32. INTM286500Foreign Permanent Establishments of UK Companies: anti-diversion rule: Chapter 13 - Low Profit Margin Exemption
  33. INTM286510Foreign Permanent Establishments of UK Companies: anti-diversion rule: Chapter 14 - Tax Exemption