Chapter 3

Permanent establishments

Summary

This chapter sets out the anti-hybrid rules relating to permanent establishment

835AE Application of chapter

Summary

This section sets out the entities and transaction(s) to which this chapter applies.

The chapter shall apply -

1. to an entity that is within the charge to foreign tax or corporation tax, and
2. to a transaction giving rise to a mismatch outcome between—
1. entities that are associated enterprises,
2. the head office of an entity and a permanent establishment of that entity, or
3. two or more permanent establishments of an entity.

Relevant Date: Finance Act 2021