The rules for calculating the foreign permanent establishments amount (see ¶764-790) are modified where the company is a small company (see ¶764-820). The size of a company is to be determined by reference to the Annex to Commission Recommendation 2003/361/EC (reproduced at ¶764-835): a small company being a micro or small enterprise as defined in the Recommendation (CTA 2009, s. 18S).

Limits applying to determine the size of a company

A company is a small company for this purpose if it employs fewer than 50 people and if its annual turnover and/or balance sheet total does not exceed €10m (art. 2(2) and (3)).

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