Commentary on Sections Part 2: Charge to corporation tax: basic provisions Overview Section 28: Borrowing: permanent establishment acting as agent or intermediary
137.This section applies the separate enterprise principle where a permanent establishment of a non-UK resident bank acts as an agent or intermediary in borrowing funds for another part of the company. It is based on paragraphs 7(1) and 10(1) and (2) of Schedule A1 to ICTA.