INTM267000 - Non-residents trading in the UK: profits of the PE: contents

1. INTM267010

   Introduction to attribution
2. INTM267020

   Construction of the domestic charge to tax on non-residents
3. INTM267030

   Domestic provisions on quantifying chargeable profits - Income Tax and Corporation Tax
4. INTM267040

   The separate entity principle and use of transfer pricing methodology
5. INTM267050

   Attribution - method of calculation of chargeable profits
6. INTM267060

   Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Comparable Uncontrolled Price
7. INTM267070

   Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Resale Method
8. INTM267080

   Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Cost Plus
9. INTM267090

   Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Profit Split Method
10. INTM267100

    Allocation of expenses in the attribution exercise
11. INTM267110

    Interest receivable by PE
12. INTM267120

    Attribution of capital to the permanent establishment - companies only: FA2003 domestic legislation - an overview
13. INTM267130

    Attribution of capital to the permanent establishment - companies only: practical 4 step approach
14. INTM267140

    Attribution of capital to the permanent establishment - companies only: alternative approaches to calculating the capital attribution tax adjustment
15. INTM267150

    Attribution of capital to the permanent establishment - companies only: practical example - non-financial business
16. INTM267160

    Treaty provisions - Article 7 (business profits article) - interaction with domestic provisions
17. INTM267170

    PE capital gains chargeable on the non-resident
18. INTM267180

    Non-residents trading in the UK: overseas permanent establishments of UK resident companies: overview
19. INTM267190

    Non-residents trading in the UK: overseas permanent establishments of UK resident companies: the capital attribution approach
20. INTM267200

    Non-residents trading in the UK: overseas permanent establishments of UK resident companies: approach to capital attribution in the host state
21. INTM267500

    UK subsidiaries of foreign banks and foreign banks trading in the UK through permanent establishments: contents