International Manual

INTM287060 - Foreign Permanent Establishments of UK Companies: exclusions and definitions: definitions

Full treaty

A full treaty territory is a territory with which the UK has a full treaty that contains a non-discrimination article applicable to permanent establishments (see CTA09/S18R).

Relevant foreign territory

In the context of the legislation at CTA09/Ch 3A, 바카라 사이트渞elevant foreign territory바카라 사이트� means a place or a territory which has a legal status and a system of law. This is because it has to be a territory with which the UK either has a full treaty, or is a place that would be capable of entering into a treaty based on the OECD Model. The legislation links the exempt profits that relate to a relevant foreign territory to the profits that would be taken into account for that territory for credit relief purposes under TIOPA10. The wording at CTA09/S18(6)(a) is 바카라 사이트渋n respect of tax paid under the law of the relevant foreign territory바카라 사이트�. This would preclude a place that has no legal existence or jurisdiction, 바카라 사이트渁 nowhere territory바카라 사이트� such as international waters.