835AI Application of Chapter 4.

This Chapter shall apply—

(a) to a company which is within the charge to domestic tax, and

(b) to a transaction that gives rise to a mismatch outcome between—

(i) entities that are associated enterprises,

(ii) the head office of an entity and a permanent establishment of that entity, or

(iii) two or more permanent establishments of an entity,

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