In addition to the rules at E6.435, the following specific provisions apply only to companies when establishing the amount of income on which credit relief is available and the amount of credit relief available (and, if profits of a foreign permanent establishment, assuming an election has not been made for exemption for the profits of a foreign permanent establishment (D4.801A)).
Quantification of income on which credit relief is available
UK company with overseas permanent establishment
The rules determining how the profits attributable to a permanent establishment (PE) for the purposes of tax credit relief are to be calculated are set out in TIOPA 2010, s 43.
The profits to be attributed to the PE are those profits of the company which are subject to the charge to corporation tax and which would have been earned by the PE had it been a 'distinct and separate enterprise' dealing independently with the company and engaged in the same or similar activities under the same or similar conditions (the 'separate enterprise principle').
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Web page updated on 17 Mar 2025 17:08