Related Commentary  Related HMRC Manuals

86(1)  This section applies in relation to a company (“the foreign company”) for an accounting period if–

(a)the company is non-UK resident in that period,

(b)it carries on a trade during that period (or part of it),

(c)a person (“the avoided PE”), whether or not UK resident, is carrying on activity in the United Kingdom in that period in connection with supplies of services, goods or other property made by the foreign company in the course of that trade,

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