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Permanent establishment

The availability of premises in the UK is an indicator (although not necessarily decisive) in determining whether or not the overseas company has a taxable presence in the UK in the form of a UK permanent establishment. In order for there to be a permanent establishment, a ‘fixed place of business’ is required. This can be specific premises acquired by the overseas company in the UK, but it can also be the home office of a single employee, which is a right to use a place of business in the UK, and activities are undertaken at the place of business by the company, either through employees or third party representatives. UK statute specifically includes the following in the definition of ‘a fixed place of business’:

1. •

   a place of management

2. •

   a branch

3. •

   an office

4. •

   a factory

5. •

   a workshop

6. •

   an installation or structure for the exploration of natural resources

7. •

   a mine, an oil or gas well, a quarry or any other place of extraction of natural resources

8. •

   a building site or construction or