835AR Application of Chapter 8.

This Chapter shall apply to—

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

(b) a mismatch outcome which arises through a transaction or series of transactions—

(i) that is or are, as the case may be, 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,

and

(ii) under which there is a payment by a company established in the State to a payee established in a state that is not a Member State.