INTM554030 | Hybrids: transfers by UK permanent establishment of a multinational company (Chapter 6): conditions to be satisfied: condition A

Condition A of s259FA TIOPA 2010 requires a company to be a multinational company.

A multinational company is defined by s259FA as a company that is

• resident for tax purposes in a territory outside the UK (the parent jurisdiction), and

• within the charge to corporation tax in the UK because it carries on a business in the UK through a permanent establishment

Company is not defined in the legislation, so takes its normal meaning under UK law.