INTM264000 - Non-residents trading in the UK: domestic law permanent establishment/branch or agency

Contents

INTM264010Introduction
INTM264020Importance of the concept of permanent establishment / branch or agency to effective taxation of non-residents
INTM264030Flow chart – Will the non-resident fall within the charge to corporation tax or income tax?
INTM264040Non-resident companies – charge to Corporation tax – permanent establishment / branch or agency
INTM264050Permanent establishment – domestic law definition – FA03/S148
INTM264060Permanent establishment - fixed place of business
INTM264070Agency permanent establishment
INTM264080Independent agents do not create a permanent establishment
INTM264090Branch or agency – statutory definition and practical recognition of a branch
INTM264100Agency – Common law concept
INTM264110Branch or agency - Case law – CIR v Brackett