INCOME TAX – corporation tax – permanent establishments in UK – applicability of intangible fixed assets election to transaction – election refused by HMRC – whether application of separate and distinct principle under UK/US Double Taxation Convention meant that transaction to be regarded as transfer of assets as appellants contended rather than sale of partnership units as HMRC contended – HMRC correct to refuse election – appeal dismissed
Citations:
[2018] UKFTT 205 (TC)
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 14 April 2022; Ref: scu.609256
