Laura Hoyland and Elizabeth Emerson (White & Case) explain the various bear-traps for a foreign company proposing to do business in the UK.
It’s easy to dismiss the UK taxation of foreign corporates as arising only if a company has any real presence in the UK be it through tax residence or other establishment. In this article we touch on UK permanent and fixed establishments of companies established outside the UK and highlight some of the key UK tax bear-traps for companies with no such presence (but which nevertheless do business in the UK) including three regimes which have sprung up only in the last five years or so.
Permanent establishments
The traditional notion that only a UK fixed establishment or UK dependent agent (or even strictly a UK independent agent acting outside its ordinary course of business) can give rise to a UK...
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Laura Hoyland and Elizabeth Emerson (White & Case) explain the various bear-traps for a foreign company proposing to do business in the UK.
It’s easy to dismiss the UK taxation of foreign corporates as arising only if a company has any real presence in the UK be it through tax residence or other establishment. In this article we touch on UK permanent and fixed establishments of companies established outside the UK and highlight some of the key UK tax bear-traps for companies with no such presence (but which nevertheless do business in the UK) including three regimes which have sprung up only in the last five years or so.
Permanent establishments
The traditional notion that only a UK fixed establishment or UK dependent agent (or even strictly a UK independent agent acting outside its ordinary course of business) can give rise to a UK...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
