INTM266000 - Non-residents trading in the UK: Treaty permanent establishment

Contents

INTM266010Why is treaty permanent establishment important?
INTM266020Potential effect on the UK domestic charge
INTM266030The Commentary to the OECD Model Treaty
INTM266040Treaty permanent Establishment - definition
INTM266050Fixed place of business permanent establishment
INTM266060Fixed place of business permanent establishment - geographic condition
INTM266070Fixed place of business permanent establishment - time condition - degree of permanence of activities
INTM266080Fixed place of business permanent establishment - personnel condition
INTM266090Fixed place of business permanent establishment - automated equipment
INTM266100Fixed place of business permanent establishment - E-commerce/E-tailers/servers/internet trading
INTM266110Fixed place of business permanent establishment - places especially included within the definition of permanent establishment
INTM266120Fixed place of business permanent establishment - activities specifically excluded from the definition of permanent establishment
INTM266130Fixed place of business permanent establishment - building sites or construction or installation projects
INTM266140Agent as permanent establishment
INTM266150Agent of independent status - Article 5(6)
INTM266160UK common law - variance with civil law