32Restriction on deductions: interest or other financing costsU.K.
This section has no associated Explanatory Notes
(1)No deduction is allowed for payments of interest or other financing costs by the permanent establishment to any other part of the non-UK resident company.
(2)But the restriction in subsection (1) does not apply to interest or other financing costs that are payable in respect of borrowing by the permanent establishment in the ordinary course of a financial business carried on by it.
(3)In subsection (2) “financial business” means any of the following—
(a)banking, deposit-taking, money-lending or debt-factoring, or a business similar to any of those, and
(b)dealing in commodity or financial futures.