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The taxation of non-permanent establishments

How can UK companies which do not have foreign permanent establishments obtain relief for state or nexus taxes charged by foreign territories?
Jackie Wheaton (Moore Stephens) reviews the key points.
 

The rise of the digital economy has given rise to calls for additional taxes on digitalised businesses which are able to access markets without having a local physical presence. At the same time US states have been trying to collect taxes from businesses without a physical presence in that state culminating in the recent US Supreme Court case of South Dakota v Wayfair Inc. (2018) 585 US (see ‘Wayfair: signposting a fairer way for global taxation?’ (Michael Cullers & Robert O’Hare) Tax Journal 20 July 2018).

US Wayfair

The decision in Wayfair has overturned a constitutional principle established under National Bellas Hess Inc. v Department of Revenue of Illinois (1967) 386 US 753 (Bellas Hess)...

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