Introduction Overview Overview Section 1144: Alternative finance arrangements
3264.This section provides that a non-UK resident company that receives sums treated as alternative finance return is not treated as having a permanent establishment in the United Kingdom merely because of anything done by the counter–party to the alternative finance arrangements under which the return is paid or by any other person acting for the non-UK resident company in relation to the arrangements. It is based on section 148(5A) of FA 2003.
3265.Alternative finance return is defined in subsection (3) by cross–reference to the application of provisions, in identical terms, contained in Part 10A of ITA (which is insertedby Schedule 2 to TIOPA andapplies for income tax purposes) and in Chapter 6 of Part 6 of CTA 2009 (which applies for corporation tax purposes). See the transitional provisions in Schedule 9 to TIOPA and Schedule 2 to CTA 2009 which provide in like terms for the application of the treatment of sums received as alternative finance return for the purposes of that Part and that Chapter.