Commentary on Sections Part 2: Charge to corporation tax: basic provisions Overview Section 23: Provision of goods or services for permanent establishment
127.This section sets out the rule for goods and services provided by the non-UK resident company to the permanent establishment. It is based on paragraph 6(1) to (3) of Schedule A1 to ICTA.
128.Although this section deals with both a deduction (expense) – see subsection (3) – and the separate enterprise principle, it is grouped with other sections dealing with the separate enterprise principle as that is the main rule here and to separate these elements would be unhelpful.