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Paragraph 3 Application of the income inclusion rule to cases involving permanent establishments

United Kingdom

(1)

Section 237 (intermediate and partially-owned parent members) is amended as follows.

(2)

For subsection (1)(b) substitute—

“(b)

it has—

(i)

a direct or indirect ownership interest in another member of the group, or

(ii)

a permanent establishment, and”.

(3)

For subsection (2)(b) substitute—

“(b)

it has—

(i)

a direct or indirect ownership interest in another member of the group, or

(ii)

a permanent establishment.”