| INTM267010 |
Introduction to attribution |
| INTM267020 |
Construction of the domestic charge to tax on non-residents |
| INTM267030 |
Domestic provisions on quantifying chargeable profits - Income Tax and Corporation Tax |
| INTM267040 |
The separate entity principle and use of transfer pricing methodology |
| INTM267050 |
Attribution - method of calculation of chargeable profits |
| INTM267060 |
Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Comparable Uncontrolled Price |
| INTM267070 |
Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Resale Method |
| INTM267080 |
Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Cost Plus |
| INTM267090 |
Case studies exploring the various transfer pricing methods that could be used in attributing profits to a permanent establishment - Profit Split Method |
| INTM267100 |
Allocation of expenses in the attribution exercise |
| INTM267110 |
Interest receivable by PE |
| INTM267120 |
Attribution of capital to the permanent establishment - companies only: FA2003 domestic legislation - an overview |
| INTM267130 |
Attribution of capital to the permanent establishment - companies only: practical 4 step approach |
| INTM267140 |
Attribution of capital to the permanent establishment - companies only: alternative approaches to calculating the capital attribution tax adjustment |
| INTM267150 |
Attribution of capital to the permanent establishment - companies only: practical example - non-financial business |
| INTM267160 |
Treaty provisions - Article 7 (business profits article) - interaction with domestic provisions |
| INTM267170 |
PE capital gains chargeable on the non-resident |
| INTM267500 |
UK subsidiaries of foreign banks and foreign banks trading in the UK through permanent establishments |
