UK taxation of foreign permanent establishments

UK taxation of foreign permanent establishments guidance:

This note only deals with the foreign branch exemption anti-diversion rules that apply to accounting periods commencing on or after 1 January 2013. For a description of...

Practice Note

ARCHIVED: This Practice Note has been archived and is not maintained. This note deals only with the anti-diversion rule that has effect for accounting periods beginning...

Practice Note

This Practice Note only describes the foreign branch exemption anti-diversion rules that apply to accounting periods commencing on or after 1 January 2013. The general...

Practice Note

This Practice Note only describes the foreign branch exemption anti-diversion rules that apply to accounting periods commencing on or after 1 January 2013. The general...

Practice Note

As explained in Practice Note: Foreign branch exemption—structure of the foreign branch exemption, the concept of the foreign permanent establishments amount (FPEA) is...

Practice Note

Why are special rules required to deal with historic losses? As further explained in Practice Note: UK taxation of foreign profits in a UK resident company, a company can...

Practice Note

As explained in Practice Note: Foreign branch exemption—foreign permanent establishments amount there are a number of rules that must be followed in calculating the...

Practice Note

Purpose of the regime The purpose of the foreign branch exemption is to exempt from UK corporation tax the profits of the worldwide permanent establishments (PEs) of a UK...

Practice Note

Many UK companies operate entirely within the boundaries of the UK, with all of their customers and suppliers being based in the UK, such that all of the company's...

Practice Note