Section 259F | Overview of Chapter

(1)This Chapter contains provision that counteracts certain excessive deductions that arise in relation to transfers of money or money's worth made, or taken to be made, by a multinational company's permanent establishment in the United Kingdom to the company in the parent jurisdiction.

(2)The Chapter counteracts such deductions by altering the corporation tax treatment of the company.

(3)Section 259FA contains the conditions that must be met for this Chapter to apply.

(4)Subsection (3) of that section defines “multinational company” and “the parent jurisdiction”.

(5)Subsection (8) of that section defines “the excessive PE deduction”.

(6)Section 259FB contains provision for the counteraction of the excessive PE deduction.

(7)See also section 259BF for the meaning of “permanent establishment”.