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Legislation
Corporation Tax Act 2010

Crossheading Circumstances where there is no permanent establishment

  • Section 1142 Agent of independent status
  • Section 1143 Preparatory or auxiliary activities
  • Section 1144 Alternative finance arrangements
  1. Circumstances where there is no permanent establishment
  2. Alternative finance arrangements

Section 1144 | Alternative finance arrangements

From legislation.gov.uk

(1)Subsection (2) applies if alternative finance return is paid to a non-UK resident company.

(2)The company is not regarded as having a permanent establishment in the United Kingdom merely by virtue of anything done for the purposes of the alternative finance arrangements—

(a)by the other party to the arrangements, or

(b)by any other person acting for the company in relation to the arrangements.

(3)In subsection (1) “alternative finance return” means alternative finance return within the application of—

(a)section 564I, 564K or 564L(2) or (3) of ITA 2007, or

(b)section 511, 512 or 513(2) or (3) of CTA 2009.

(4)In subsection (2) the reference to “the alternative finance arrangements” is a reference to the alternative finance arrangements under which the alternative finance return mentioned in subsection (1) is paid.

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