The introduction of the permanent establishment concept into domestic law in 2003 brought with it art. 7(2) attribution rules for corporation tax purposes:

‘The profits of the non-UK resident company that are attributable to the permanent establishment are those that the establishment would have made if it were a distinct and separate enterprise which –

(a)engaged in the same or similar activities under the same or similar conditions, and

(b)dealing wholly independently with the non-UK resident company.69

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