Revenue Note for Guidance

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Revenue Note for Guidance

835AI Application of chapter

Summary

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

Details

This chapter shall apply -

  1. to a company which is within the charge to domestic tax, and
  2. to a transaction that gives 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,

other than where that transaction is an on-market hybrid transfer.

Relevant Date: Finance Act 2019