21 Permanent establishments: preparatory or auxiliary activities

21  Permanent establishments: preparatory or auxiliary activities

(1)     Section 1143 of CTA 2010 (permanent establishments: preparatory or auxiliary activities) is amended as follows.

(2)     In subsection (2), at the end insert “and are not part of a fragmented business operation”.

(3)     After subsection (2) insert—

“(2A)     Activities are “part of a fragmented business operation” if—

(a)     they are carried on (whether at the same place or at different places in the same territory) by the company or a person closely related to the company,

(b)     they constitute complementary functions that are part of a cohesive business operation, and

(c)     subsection (2B) applies.

(2B)     This subsection applies if—

(a)     the overall activity resulting from the combination of the functions mentioned

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