Section 21 The separate enterprise principleC1

The profits of the non-UK resident company that are attributable to the permanent establishment are those that the establishment F1might be expected to make if it were a F2separate and independent enterprise engaged in the same or similar activities under the same or similar conditions, taking into account the functions performed, assets used and risks assumed by the non-UK resident company through the permanent establishment and through the other parts of the non-UK resident company.

In applying subsection (1) assume that—

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