UK profits and permanent establishments

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Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
Practice notes
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
Practice notes
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 sale of all the shares...
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9th Nov
Practice notes
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
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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9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent UK profits and permanent establishments content

Practice notes
A non-UK resident company doing business in the UK has a choice as to whether to form a subsidiary company in the UK, or to operate through a...
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15th Apr
Practice notes
This Practice Note looks at what constitutes a UK permanent establishment (PE) in the context of a trade of dealing in property. Prior to 5 July 2016...
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Produced in partnership with Charles Goddard of Rosetta Tax 9th Apr
Practice notes
A non-UK resident company trading in the UK through a permanent establishment (PE) will be chargeable to corporation tax on the profits associated...
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9th Apr
Practice notes
When a company that is resident outside the UK starts doing business in the UK, it will want to know whether and to what extent the activities of that...
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9th Apr
Practice notes
Coronavirus (COVID-19): For information on the inadvertent creation of permanent establishments as a result of the coronavirus pandemic, see Q&A:...
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9th Apr
Practice notes
Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty territory (ie not resident in a territory with which the UK...
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9th Apr
Practice notes
From April 2019, the profit fragmentation rules aim to prevent UK-resident individuals, including individual members of a partnership, and UK-resident...
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9th Apr
Q&As
The charge to UK corporation tax on a non-UK resident company depends (subject to special rules for companies that deal in or develop UK land) on the...
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15th Feb
Q&As
Companies HouseThe statutory rules in relation to overseas companies are set out in Part 34 of the Companies Act 2006 (CA 2006) and the Overseas...
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9th Feb
Q&As
Whether a single employee working in the UK for a non-UK company could give rise to a taxable presence for the non-UK company is considered below.Risk...
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8th Dec
Q&As
In this Q&A we have assumed that the lending in question is between two companies (or is within the same company) rather than between individuals,...
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29th Nov

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