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Contents

Legislation
Taxation (International and Other Provisions) Act 2010

Chapter 11 The excluded territories exemption

  • Section 371KA Introduction to Chapter
  • Section 371KB The basic rule
  • Section 371KC How to determine the territory in which a CFC is resident
  • Section 371KD What is “the threshold amount”?
  • Section 371KE Category A income: the basic rule
  • Section 371KF Category A income: permanent establishments in excluded territories
  • Section 371KG Category B income
  • Section 371KH Category C income
  • Section 371KI Category D income
  • Section 371KJ The IP condition
  1. Chapter 11 · The excluded territories exemption
  2. Category A income: permanent establishments in excluded territories

Section 371KF | Category A income: permanent establishments in excluded territories

From legislation.gov.uk

(1)This section applies if—

(a)a CFC's category A income for an accounting period would include (apart from this section) the gross amount of any relevant income which arises from the activities of a permanent establishment (“PE”) which the CFC has in a territory outside the CFC's territory, and

(b)the territory in which PE is established is an excluded territory.

(2)The gross amount of that relevant income is to be included in the CFC's category A income only so far as it would also have been included had the references in section 371KE(3) to (5) to the CFC's territory instead been references to the territory in which PE is established.

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