UK profits and permanent establishments

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Practice notes
VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes
Why have a tax covenant?It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a...
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent UK profits and permanent establishments content

Q&As
Can a non-UK incorporated company have a UK taxable presence if it has an employee operating in the UK?Whether a single employee working in the UK for...
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17th Sep
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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6th Sep
Q&As
When a non-UK company has a UK permanent establishment or becomes UK tax resident, how and when must it inform Companies House and HMRC? What happens...
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6th Sep
Practice notes
What constitutes a UK permanent establishment in a property context?This Practice Note looks at what constitutes a UK permanent establishment (PE) in...
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Produced in partnership with Charles Goddard of Rosetta Tax 16th Aug
Q&As
What method will HMRC use when determining an arm's length interest rate on a related party loan?In this Q&A we have assumed that the lending in...
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16th Aug
Q&As
When considering whether a non-UK resident company has a UK permanent establishment, what importance is attached to the presence of employees in the...
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16th Aug
Practice notes
Profit fragmentation and tax avoidanceFrom April 2019, the profit fragmentation rules aim to prevent UK-resident individuals, including individual...
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15th Aug
Practice notes
What is a UK permanent establishment?Coronavirus (COVID-19): For information on the inadvertent creation of permanent establishments as a result of...
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15th Aug
Practice notes
When does the UK tax non-resident companies?When a company that is resident outside the UK starts doing business in the UK, it will want to know...
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15th Aug
Practice notes
Subsidiary versus permanent establishmentA non-UK resident company doing business in the UK has a choice as to whether to form a subsidiary company in...
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15th Aug
Practice notes
How is a UK permanent establishment taxed?A non-UK resident company trading in the UK through a permanent establishment (PE) will be chargeable to...
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15th Aug

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