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Chapter DT1951

Cited authorities 1 Cited in Related
Vincent
Published date20 May 2016
Record NumberDT1951

ICTA88/S338 (4) denies a deduction for charges paid by a non-resident company to a non- resident person to the extent that they fall within Sub-section (3)(a) (yearly interest etc.), so that a permanent establishment in the United Kingdom of a non-resident company would not normally be entitled to a deduction for such charges where paid by the company to a non- resident. This prohibition may be overridden by that part of the non-discrimination Article which requires a permanent establishment to be taxed no less favourably than the taxation levied on United Kingdom enterprises carrying on the same activities.

A permanent establishment of a non- resident enterprise will therefore be entitled to deduct the charges it...

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