Related Commentary  

78(1)  For the purposes of sections 71A to 76 “overseas permanent establishment” means, in relation to a company, a permanent establishment through which the company carries on a trade in a territory outside the United Kingdom.

78(2)  In subsection (1) “permanent establishment”

(a)if the arrangements are double taxation arrangements which contain a relevant non-discrimination provision, has the meaning given by the arrangements, and

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