Related Commentary  Related HMRC Manuals

1143(1)  If the condition in subsection (2) is met, a company is not regarded as having a permanent establishment in a territory by reason of the fact that–

(a)a fixed place of business is maintained there for the purpose of carrying on activities for the company, or

(b)an agent carries on activities there for and on behalf of the company.

1143(2)  The condition is that, in relation to the business of the company as a whole, the activities carried on are only of a preparatory or auxiliary character and are not part of a fragmented business operation.

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