GIM10200 - Non-resident insurers: the scope of UK taxing rights: accounting periods beginning before 1 January 2003: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: mutual agreement procedure

Where the UK seeks to attribute to a branch income or gains on assets not appropriated to the branch, the company may seek to invoke the mutual agreement procedure provided by the treaty. This is because it alleges that the parent state, where it is an exemption country (one that exempts from tax overseas branches) will tax the income as well as it does not regard it as income of an overseas branch. A submission should be made in any case where the mutual agreement procedure is requested.