Setting up in the UK ― branch or subsidiary

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

Setting up in the UK ― branch or subsidiary

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
imgtext

A company doing business in the UK may initially undertake activities without a taxable presence in the UK.

However, where activities will actually be undertaken in the UK, the parent should consider whether to set up in the UK through a branch (which will usually be treated for tax purposes as a permanent establishment (PE)), or a subsidiary.

An overseas company may also acquire a UK PE without intending to do so. Where the business in the UK develops to the point that the company has a fixed place of business in the UK through which the business of the company is carried on, it will have a PE. The company may also acquire a UK PE through a dependent agent. For chargeable periods beginning on or after 1 January 2026, it can arise where a person acting on behalf of the company habitually concludes contracts, or habitually plays the principal role leading to contracts that are routinely concluded without material modification by the company. For chargeable periods beginning before

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™
Powered by Tolley+™

Popular Articles

Settlor-interested trusts

Settlor-interested trustsWhat is a settlor-interested trust?A settlor-interested trust is one where the person who created the trust, the settlor, has kept for himself some or all of the benefits attaching to the property which he has given away. A straightforward example is where a settlor

14 Jul 2020 13:38 | Produced by Tolley Read more Read more

Foreign exchange issues

Foreign exchange issuesOverview of foreign exchange provisionsForeign exchange (FX) movements are generally taxed following the rules applicable to the underlying income, expenditure, asset or liability on which they arise, broadly as follows:Capital assetsOn a realisation basis (ie on disposal)

14 Jul 2020 11:44 | Produced by Tolley Read more Read more

BPR ― trading and investment businesses

BPR ― trading and investment businessesIntroductionThe basic qualification rules for business property relief (BPR) are illustrated in the Flowchart ― trading or investment business for BPR purposes.For an overview of BPR, see the BPR overview guidance note.Relevant business propertyThe main

14 Jul 2020 15:36 | Produced by Tolley Read more Read more