Second branch related question the day . . . .
Can a UK permanent establishment of an overseas company claim AIA (assuming it isn't used up elsewhere)? I cannot see anything that suggests no (and presumably it would contravene non-discrimination clauses [parent co is German] if it wasn't available). Reason I have doubt is because a colleague of mine has a 'vague recollection' of AIA not being available. Also, a claim would take my company from tax paying to not, so I feel like I need concrete evidence either way.
As far as I can see:
- UK branches are allowed any deduction a UK company would be (subject to interest, royalties, non-arms length etc)
- AIA is available to individuals and companies (we are a UK branch of a foreign company, but a company non-the-less)