C1C2Part 2Double taxation relief
Annotations:
Modifications etc. (not altering text)
C2
Pt. 2 applied by 2010 c. 4, s. 269DL(6) (as inserted (with effect in accordance with Sch. 3 Pt. 3 of the amending Act) by Finance (No. 2) Act 2015 (c. 33), Sch. 3 para. 1)
C2CHAPTER 2Double taxation relief by way of credit
Unrelieved foreign tax on profits of overseas permanent establishment
76Former and subsequent establishments regarded as distinct establishments
1
If the company—
a
at any time ceases to have a particular overseas permanent establishment in a particular territory (“the old establishment”), but
b
subsequently again has an overseas permanent establishment in that territory (“the new establishment”),
the old establishment and the new establishment are, for the purposes of the provisions of sections 72 to 78 other than the excepted provisions, to be regarded as different overseas permanent establishments.
2
In subsection (1) “the excepted provisions” means sections 73(2), 75 and 77.
Pt. 2 modified by 1988 c. 1, Sch. 19ABA paras. 26-28 (as inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 34(3) (with Sch. 9 paras. 1-9, 22))