Corporation Tax Act 2009 section 20

Profits attributable to permanent establishment: introduction

Section 20 introduces the framework of rules used to determine how much of a non-UK resident company's profits are attributable to its permanent establishment in the United Kingdom.

• Sections 21 to 32 of the Corporation Tax Act 2009 set out the rules for calculating the profits of a non-UK resident company that are attributable to its UK permanent establishment.
• Within that group of sections, sections 21 to 28 specifically deal with the separate enterprise principle, which broadly requires the permanent establishment to be treated as if it were a distinct and independent entity.
• Additional rules in section 1152 of the Corporation Tax Act 2010 allow profits from certain investment transactions carried out through investment managers to be disregarded when calculating the profits attributable to a permanent establishment.
• This section is introductory and signposting in nature; the detailed computational rules are contained in the sections that follow.