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Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading Unrelieved foreign tax on profits of overseas permanent establishment

  • Section 72 Application of section 73(1)
  • Section 73 Carry-forward and carry-back of unrelieved foreign tax
  • Section 74 Rules for carrying back unrelieved foreign tax
  • Section 75 Two or more establishments treated as a single establishment
  • Section 76 Former and subsequent establishments regarded as distinct establishments
  • Section 77 Claims for relief under section 73(1)
  • Section 78 Meaning of “overseas permanent establishment”
  1. Unrelieved foreign tax on profits of overseas permanent establishment
  2. Two or more establishments treated as a single establishment

Section 75 | Two or more establishments treated as a single establishment

From legislation.gov.uk

(1)Subsection (2) applies if, under the law of a territory outside the United Kingdom, tax is charged in respect of the profits of two or more overseas permanent establishments in that territory, taken together.

(2)For the purposes of the provisions of sections 72 to 78 other than the excepted provisions, those overseas permanent establishments are to be treated as if they together constituted a single overseas permanent establishment.

(3)In subsection (2) “the excepted provisions” means section 73(2), this section and section 77.

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