Unless one of the exceptions listed below applies, taxable diverted profits arise to a company (the foreign company) in connection with avoiding a UK taxable presence if:

(1)the foreign company is non-UK resident in that period;

(2)it carries on a trade during that period (or part of it);

(3)a person (the avoided PE) (whether or not UK resident) is carrying on activity in the UK 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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