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SCHEDULES

Valid from 10/07/2003

SCHEDULE A1U.K.Determination of profits attributable to permanent establishment: supplementary provisions

Part 2 U.K.General provisions

Provision of goods or services for permanent establishmentU.K.

6(1)This paragraph applies where the non-resident company provides the permanent establishment with goods or services.

(2)If the goods or services are of a kind that the company supplies, in the ordinary course of its business, to third parties dealing with it at arm’s length, the matter is dealt with as a transaction to which the separate enterprise principle applies.

(3)If not, the matter is dealt with as an expense incurred by the non-resident company for the purposes of the permanent establishment.