Branch Capital – Five Easy Steps?

In this article Simon Leach of the PricewaterhouseCoopers Banking & Capital Markets tax team looks at the draft Guidance Notes on the attribution of capital to banking PEs published by the Inland Revenue on 27 November 2002.

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Background

On 27 November 2002 the Inland Revenue published revised draft legislation and Guidance Notes setting out their views as to how the proposed branch capital attribution rules set out in new s.11AA, ICTA 1988 should be applied by banks in practice. This article looks briefly at the amendments to the draft legislation (originally published in July 2002 and discussed in the September 2002 of FITAR edition) before going on to look at the Guidance Notes in more detail.