Income Tax Act 2007 section 926

Interpretation of Chapter

Section 926 provides definitions and interpretation rules for the Chapter dealing with manufactured payments, ensuring consistent terminology and clarifying how references to branches and agencies apply to companies.

• Expressions used in this Chapter carry the same meaning as in Chapter 2 of Part 11 (manufactured payments and repos), avoiding the need to duplicate definitions.
• For companies, any reference to a trade carried on through a "branch or agency" must be read as a reference to a trade carried on through a "permanent establishment".
• This distinction matters because a non-UK resident company can trade in the UK through a branch or agency without necessarily having a permanent establishment.
• The rule ensures that the tax treatment of manufactured payments aligns with the internationally recognised concept of permanent establishment when applied to companies.