CTM80305 - Groups: group relief: the international aspect -permanent establishments
CTA10/S107
A non-resident company that carries on a trade in the UK through a permanent establishment is within the charge to CT and so can claim and surrender group relief (CTM80150).
CTA10/S107 contains special rules for determining the amount, if any, that can be surrendered. »Ê¹ÚÌåÓýappre is guidance on these rules at CTM80310.
For companies resident in the UK trading overseas through a permanent establishment, there are also special rules. »Ê¹ÚÌåÓýappre is guidance on these rules at CTM80350.