Commentary

A8.107 Permanent establishments and coronavirus (COVID-19)

Administration and compliance

A8.107 Permanent establishments and coronavirus (COVID-19)

A8.107 Permanent establishments and coronavirus (COVID-19)

The increase in the number of employees working from home during the coronavirus pandemic could lead to a risk of creating unintended permanent establishments in the UK and in other countries. This will be relevant where the employee is located in a different country to their employer and will be of particular concern where the employee has a senior role and / or enters into contracts on behalf of the non-resident employer.

In the UK, if a non-resident company is treated as trading through a UK permanent establishment (PE), all of its income

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