Income Tax (Earnings and Pensions) Act 2003 section 14A

The UK permanent establishment requirement

Section 14A sets out how a company meets the UK permanent establishment requirement, either directly or through another group member.

  • The UK permanent establishment requirement is met if either of two conditions is satisfied
  • Condition A: the company itself has a permanent establishment in the United Kingdom
  • Condition B: the company is a parent company and another group member both carries on trading activities and has a UK permanent establishment
  • Only one of the two conditions needs to be met for the requirement to be satisfied

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