81 Non-UK company: involvement of entities or transactions lacking economic substance

81  Non-UK company: involvement of entities or transactions lacking economic substance

(1)     This section applies in relation to a company (“the foreign company”) for an accounting period if—

(a)     it is non-UK resident in that period,

(b)     by reason of the foreign company carrying on a trade in the United Kingdom through a permanent establishment in the United Kingdom (“UKPE”), Chapter 4 of Part 2 of CTA 2009 (non-UK resident companies: chargeable profits) applies to determine the chargeable profits of the

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