88 Calculation of taxable diverted profits in section 86 case: introduction
Finance Act 2015 (2015 c 11) | Legislation

Calculation of Taxable Diverted Profits: section 86 Cases

88  Calculation of taxable diverted profits in section 86 case: introduction

(1)     If section 86 applies for an accounting period, section 89, 90 or 91 applies to determine the taxable diverted profits of the foreign company.

(2)     But see also section 97 for how a designated HMRC officer estimates those profits when issuing a preliminary notice under section 93 or a charging notice under section 95.

(3)     Subsections (4) to (12) define some key expressions used in sections 89 to 91 and this section.

(4)     “The foreign company” has the same meaning as in section 86.

[(5)     Notional PE profits”, in relation to an accounting period, means an amount equal to the sum of—

(a)     the amount of profits (if any) which would have been the chargeable profits of the foreign company for that period, attributable (in accordance with sections 20 to 32 of CTA 2009) to the avoided PE, had the avoided PE been a permanent establishment in the United Kingdom through which the foreign company carried on the trade mentioned in section 86(1)(b), and

(b)

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