UK taxation of foreign permanent establishments

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Practice notes
How employment income is taxed—non-cash earnings or benefitsIn addition to cash earnings, such as wages or salaries, many reward packages include...
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19th May
Practice notes
VAT treatment of damages and compensation paymentsFORTHCOMING CHANGE: HMRC is in the process of revising Revenue and Customs Brief 12 (2020) on the...
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19th May
Practice notes
Key tax consequences of an insolvent liquidationThis Practice Note outlines:•the main corporation tax consequences when a UK incorporated company...
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Produced in partnership with Julia Fox of Deloitte LLP and Anthony Davis 19th May
Practice notes
EIS—deferred gain becomes chargeable to CGTCoronavirus (COVID-19): In response to the coronavirus (COVID-19) pandemic, the government introduced a...
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19th May
Practice notes
Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the...
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19th May
Practice notes
Corporation tax—connected personsThis Practice Note looks at the meaning of connected persons within sections 1122 and 1123 of the Corporation Tax Act...
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19th May
Practice notes
Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)STOP PRESS relating to property rich collective investment...
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19th May
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
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
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
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
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
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
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 taxation of foreign permanent establishments content

Practice notes
Foreign branch exemption—historic lossesWhy are special rules required to deal with historic losses?As further explained in Practice Note: UK taxation...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 31st Jul
Practice notes
UK taxation of foreign profits in a UK resident companyMany UK companies operate entirely within the boundaries of the UK, with all of their customers...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 31st Jul
Practice notes
Foreign branch exemption—impact on other tax rulesAs explained in Practice Note: Foreign branch exemption—foreign permanent establishments amount...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 31st Jul
Practice notes
Foreign branch exemption—anti-diversion after 1 January 2013This note only deals with the foreign branch exemption anti-diversion rules that apply to...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 31st Jul
Practice notes
Foreign branch exemption—anti-diversion before 1 January 2013 [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.This note...
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31st Jul
Practice notes
Foreign branch exemption—diverted profits gatewayThis Practice Note only describes the foreign branch exemption anti-diversion rules that apply to...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 30th Jul
Practice notes
Structure of the foreign branch exemptionPurpose of the regimeThe purpose of the foreign branch exemption is to exempt from UK corporation tax the...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 30th Jul
Practice notes
Foreign branch exemption—foreign permanent establishments amountAs explained in Practice Note: Foreign branch exemption—structure of the foreign...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 30th Jul
Practice notes
Foreign branch exemption—exemptions from the anti-diversion ruleThis Practice Note only describes the foreign branch exemption anti-diversion rules...
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Produced in partnership with Robert O’Hare of Squire Patton Boggs 30th Jul

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