835AI Application of chapter

Summary

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

Details

This chapter shall apply -

1. to a company which is within the charge to domestic tax, and
2. to a transaction that gives 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,

other than where that transaction is an on-market hybrid transfer.

Relevant Date: Finance Act 2021