S820 includes provisions that correspond to TCGA92/S140C, (CG45730 onwards), which gives effect to parts of the EC Mergers Directive (No 90/434/EEC) on cross-border business reorganisations. It provides for relief in the form of notional foreign tax on transfers where a UK company carries on a trade through a permanent establishment in another EU member state. This relief cannot be claimed if relief is given under S827 (see CIRD42040).

(FA03/S153 (1) substituted the words ‘permanent establishment’ for ‘branch or agency’ effective for all accounting periods beginning on or after 1 January 2003.)

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