Paragraph 21

In section 919 (manufactured interest on UK securities: payments by UK residents etc), after subsection (1) insert—

“(1A)

But this section does not apply if—

(a)

the manufactured interest is paid by a UK resident company in the course of a trade carried on through a permanent establishment in a territory outside the United Kingdom, and

(b)

section 18A of CTA 2009 has effect in relation to the company for the accounting period in which it is paid.”