IEIM541300 - Action 5 rulings: Types of rulings to exchange: Rulings relating to permanent establishments

IEIM541300: Action 5 rulings: Types of rulings to exchange: Rulings relating to permanent establishments

Rulings related to permanent establishments are automatically exchanged with relevant jurisdictions under Action 5. »Ê¹ÚÌåÓýapp rules apply equally to situations where the permanent establishment is in the UK, and where there is an overseas permanent establishment of a UK company.

»Ê¹ÚÌåÓýapp ruling may either:

  • Relate to the existence or absence of a permanent establishment (IEIM541310)
  • Provide for the attribution of income or profit between parts of a business enterprise which operates in more than one country, where questions may arise as to the taxable income to be recognised in any such part (IEIM541320)