Permanent establishment

A fixed place of business through which the business of an enterprise is wholly or partly carried on, including a place of management, a branch, an office, a factory or a workshop. An agent acting for a non-UK resident company who habitually exercises (in the UK) authority to do business on the company's behalf may also create a permanent establishment. This term usually arises in the context of double taxation treaties (www.practicallaw.com/A34913). The usual rule in a comprehensive double tax treaty is that only the country of residence can tax the profits of a trade or business, unless they arise from a permanent establishment in the other country. For a detailed discussion of permanent establishments and their tax treatment, see Practice note, Companies: UK residence and permanent establishments (www.practicallaw.com/4-204-0101).

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