This applies for relevant periods beginning before 1 January 2013.

CTA09/S18H: Condition B

Condition B of the motive test in CTA09/S18H(6) is based on the diversion of profits leg of the existing CFC motive test. It will apply to permanent establishments which are used to reduce UK tax but which may not be undertaking transactions directly with the UK. This condition therefore focuses on whether the diversion of profits from the UK is one of the main reasons for the company carrying on its business through that PE.

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