Introduction Details of the Section
2.Subsection (1) states that the section applies where section 86 applies for an accounting period and the mismatch condition is not met. The mismatch condition is defined in subsection (2) of section 86.
3.Subsection (2) determines the taxable diverted profits that arise to the foreign company in the accounting period. These are equal to the notional PE profits for the period. The notional PE profits are defined in subsection (4) of section 88.