159 Permanent establishment income and expense attribution
Finance (No 2) Act 2023 (2023 c 30) | Legislation

Adjustments only applicable to permanent establishments

159  Permanent establishment income and expense attribution

(1)     Where a member of a multinational group is a permanent establishment falling within paragraph (a) of section 232(2) (entity treated as permanent establishment in accordance with tax treaty), its underlying profits are to be adjusted so that they[—

(a)     reflect all amounts of income and expense that are attributable to it in accordance with the tax treaty under which it is treated as a permanent

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