(a) of the same length as the distribution period, and (4) The period referred to in sub-paragraph (3) is a period. (3) If the first corresponding accounting period is shorter than the distribution period, any subsequent accounting period of the recipient company beginning before the end of the period specified in sub-paragraph (4) is a corresponding accounting period. Unless that accounting period is shorter than the distribution period, it is the recipient company’s only corresponding accounting period. (2) The accounting period of a recipient company that includes the last day of the distribution period is its first corresponding accounting period. If there is more than one such period, excess NCDs must be allocated to the first to the full extent possible before any allocation is made to the second, and so on. (5) References in this paragraph to a financial asset include any financial risk in relation to a loan, or potential loan, that is capable of giving rise to fees or other receipts and for which the holding of capital is required (or would be required if the transaction were between parties at arm’s length).Īllocation of excess NCDs: period or periods to which amount to be allocated U.K.Ĩ (1) Excess NCDs falling to be allocated to another company under paragraph 7 (allocation to other group companies) may be allocated to any accounting period identified by this paragraph as a corresponding accounting period. (b) administering the loan (including handling and monitoring the service of it) and holding and controlling any securities pledged. (a) concluding the loan agreement and disbursing the proceeds of the loan (4) Account may also be taken of the extent to which the permanent establishment is responsible for. (d) deciding whether, and if so on what conditions, to make or extend the loan.
(c) negotiating the terms of the loan with the borrower (b) establishing the potential borrower’s credit rating and the risk involved in providing credit (3) Particular account shall be taken of the extent to which the permanent establishment is responsible for. (2) The following provisions have effect as regards the factors to be taken into account. Loans by non-resident banks: attribution of financial assets and profits arising U.K.ĩ (1) In accordance with the separate enterprise principle, loans and other financial assets, and profits arising from them, are attributed to a permanent establishment to the extent that they can reasonably be regarded as having been generated by the activities of the permanent establishment.
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