239 Location of entities
Finance (No 2) Act 2023 (2023 c 30) | Legislation

Provision relating to location of entities

239  Location of entities

(1)     The normal rule for determining, for the purposes of this Part, the territory in which an entity is located is that—

(a)     if it is tax resident in a territory based on its place of management or place of creation, or based on similar criteria, it is located in that territory, or

(b)     if it is not tax resident in any territory based on such criteria, it is located in the territory in which it was created.

(2)     But subsection (1) does not apply to a flow-through entity or a permanent establishment (as to which, see section 240).

(3)     Where, in an accounting period, an entity is tax resident based on its place of management, place of creation or similar criteria in more than one territory and—

(a)

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