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.