Related Commentary  Related HMRC Manuals

43(1)  This section applies in determining for the purposes of section 42(2) the amount of the profits of a UK resident company on which corporation tax is or would be chargeable that is attributable to a permanent establishment of the company in a territory outside the United Kingdom.

43(2)  The amount of the profits of the company that is attributable to the permanent establishment is the amount that the permanent establishment would have made if it were a distinct and separate enterprise which–

(a)engaged in the same or similar activities under the same or similar conditions, and

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