Introduction

Before it was amended by FA 2011, TIOPA10/S43 applied the permanent establishment (PE) provisions of Chapter 4, Part 2 CTA09 (previously ICTA88/S11AA) in determining for the purposes of S42(2) how much of a UK resident company's chargeable profits was attributable to an overseas PE of the company.

TIOPA10/S43 as amended by FA 2011 introduces specific rules for the PEs of UK resident companies, particularly in relation to the attribution of capital. Although this change was introduced alongside branch exemption it applies to all overseas PEs of UK resident companies whether or not the company has made an election under CTA09/S18A (see the [## Introduction {#IDASF4QH}