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A UK company expanding overseas may do so in a variety of ways, including:

1. •

   distance trading from the UK, with no local presence

2. •

   a branch (also often referred to as a permanent establishment), which may be formed by just one employee working from home

3. •

   a fully established local subsidiary

The decision to trade in another jurisdiction involves a number of considerations, both commercial and tax-related. It is important, therefore, that advice is taken by the company at the outset, not only in relation to tax but on the wider business implications. However, some companies may inadvertently start trading overseas, perhaps because they have an employee or agent of the company in another jurisdiction. It is therefore important to consider the issues covered in this series of notes whenever there is a change to a company or its trade which touches on foreign jurisdictions in any way.

This note deals only in broad outline with the UK tax issues which should be considered for companies. In addition, the tax regime