Part 7Tax treatment of financing costs and income
CHAPTER 5Intra-group financing income where payer denied deduction
301Meaning of “tax-resident” and “EEA territory”
1
For the purposes of this Chapter, the payer is “tax-resident” in a territory if it is liable, under the law of that territory, to tax by reason of domicile, residence or place of management.
2
In this Chapter “EEA territory” means a territory outside the United Kingdom that is within the European Economic Area.