Revenue Note for Guidance

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Revenue Note for Guidance

Chapter 3

Permanent establishments

Summary

This chapter sets out the anti-hybrid rules relating to permanent establishment

835AE Application of chapter

Summary

This section sets out the entities and transaction(s) to which this chapter applies.

The chapter shall apply -

  1. to an entity that is within the charge to foreign tax or corporation tax, and
  2. to a transaction giving rise to a mismatch outcome between—
    1. entities that are associated enterprises,
    2. the head office of an entity and a permanent establishment of that entity, or
    3. two or more permanent establishments of an entity.

Relevant Date: Finance Act 2019