This Chapter shall apply to -
(a) a company which is within the charge to domestic tax, and
(b) a mismatch outcome which arises through a transaction or series of transactions -
(i) that is or are, as the case may be, between -
(I) entities that are associated enterprises,
(II) the head office of an entity and a permanent establishment of that entity, or
(III) two or more permanent establishments of an entity,
and
(ii) under which there is a payment by a company established in the State to a payee established in a state that is not a Member State.