The International Controlled Transaction Reporting Regulations 2026
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Change 1
14 Specification of specified international controlled transaction
Unless an exception in regulation 15 applies, an international controlled transaction is a specified international controlled transaction where it meets the— (a) transfer pricing condition; (b) permanent establishment condition and if, for the purpose of applying Chapter 3A or 4 of Part 2 of CTA 2009 (profits of permanent establishments)— (i) it is treated as having occurred between the permanent establishment and the other parts of the enterprise of which the permanent establishment is a part for the purposes of applying section 21 of CTA 2009 or for the purpose of exemption adjustments made under section 18A of CTA 2009, or (ii) the participation condition is met, or treated as met, in relation to the provision made or imposed by means of that transaction and it is attributable, either wholly or in part, to the— (aa) permanent establishment of a non-UK resident company in the United Kingdom, or (bb) foreign permanent establishment of a UK resident company, for the purpose of exemption adjustments made under section 18A of CTA 2009.
14 Specification of specified international controlled transaction
Unless an exception in regulation 15 applies, an international controlled transaction is a specified international controlled transaction where it meets the— (a) transfer pricing condition; (b) permanent establishment condition and if, for the purpose of applying Chapter 3A or 4 of Part 2 of CTA 2009 (profits of permanent establishments)— (i) it is treated as having occurred between the permanent establishment and the other parts of the enterprise of which the permanent establishment is a part for the purposes of applying section 21 of CTA 2009 or for the purpose of exemption adjustments made under section 18A of CTA 2009, or (ii) the participation condition is met, or treated as met, in relation to the provision made or imposed by means of that transaction and it is attributable, either wholly or in part, to the— (aa) permanent establishment of a non-UK resident company in the United Kingdom, or (bb) foreign permanent establishment of a UK resident company, for the purpose of exemption adjustments made under section 18A of CTA 2009.
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