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There are two conditions which must both be met for the rules restricting a double deduction to apply, as follows¹:

1. Ìý

   •ÌýÌýÌýÌý a company is either a dual resident company, or a relevant multinational company

2. Ìý

   •ÌýÌýÌýÌý there is an amount which, it is reasonable to suppose could, by reason of the company being a dual resident company or relevant multinational company, be deducted from the income of the company for an accounting period for corporation tax purposes and be deducted from the income of the company for a taxable period for the purposes of an overseas tax (the dual territory double deduction amount)

For these purposes, a dual resident company is one which is both resident in the UK and another territory. A relevant multinational company is one which is subject to tax under the law of a territory outside its territory of residence, by reason of carrying on a business through a PE there (the PE jurisdiction) and the UK is either the PE jurisdiction or the territory of residence