INTM337340 | Double Taxation applications and claims: Applicants/claimants: Claims by financial concerns under Business Profits Article: Requests to extend the provisions to other income

From HM Revenue & Customs · International Manual

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

and

  • 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).