The concept of a permanent establishment (PE) is much used in double taxation treaties and, where applicable, the treaty definition overrides the statutory definition in CTA 2010, Pt. 24, Ch. 2. The statutory definition is nevertheless intended to accord, in large part, with that in common use in the UK’s tax treaties.

The statutory definition provides that a company has a PE in a territory if (and only if) either:

(1)it carries on business (wholly or partly) through a ‘fixed place of business’ in that territory; or

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