»Ê¹ÚÌåÓýapp

Payer is within the charge to CT

»Ê¹ÚÌåÓýapp counteraction where the payer is within the charge to UK corporation tax is set out at s259HC TIOPA 2010. »Ê¹ÚÌåÓýapp payer’s deduction for the payment period is reduced by an amount equal to the multinational payee deduction/non-inclusion mismatch.

From 1 January 2020: Payee is a UK resident multinational company

If the payee that is a multinational company

• is UK resident for the payment period, and
• under the law of the parent jurisdiction is regarded as carrying on a business in a PE jurisdiction through a permanent establishment in that territory, but
• is not regarded as doing so by the law of that jurisdiction

an amount equal to the multinational payee deduction/non-inclusion mismatch is treated as arising to the multinational company ion the UK and nowhere else for the payment period.