160 Attribution of losses between permanent establishment and main entity
Finance (No 2) Act 2023 (2023 c 30) | Legislation

160  Attribution of losses between permanent establishment and main entity

(1)     Subsection (2) applies where, on determining (ignoring this section) the adjusted profits of a member of a multinational group that is a permanent establishment for an accounting period (“the relevant period”), that member has a loss.

(2)     So much of that loss as—

(a)     is treated as an allowable expense of the main entity for the purposes of the computation of tax in the territory in which the main

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