For each relevant foreign territory, the relevant profits amount is the amount of profits, and the relevant losses amount is the amount of losses, attributable to the PE in that territory by reference to:

for full treaty territories (¶764-805) the treaty in place between the UK and the foreign territory; or

in any other case, the 2010 OECD Model Tax Convention (or replacement document designated by Treasury Order, no such orders having been made as yet),

for the purpose of ascertaining the amount of credit allowed under TIOPA 2010 for foreign tax paid (¶173-500) (CTA 2009, s. 18A(6) and (7); CTA 2009, s. 18S).

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