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Section 259BF Meaning of “permanent establishment”F1

(1)

In this Part “permanent establishment” means anything that is—

(a)

a permanent establishment of a company within the meaning of the Corporation Tax Acts (see section 1119 of CTA 2010), or

(b)

within any similar concept under the law of a territory outside the United Kingdom.

(2)

A concept is not outside the scope of subsection (1)(b) by reason only that it is not based on Article 5 of a Model Tax Convention on Income and Capital published by the Organisation for Economic Cooperation and Development.

Annotations

Textual amendments

F1

Pt. 6A inserted (with effect in accordance with Sch. 10 paras. 18-21 of the amending Act) by Finance Act 2016 (c. 24), Sch. 10 para. 1