Background

The COVID-19 pandemic has resulted in significant disruption to international travel and business operations, including the locations of directors, employees and other individuals.

HMRC is very sympathetic to the disruption that is being endured.

We have been asked about HMRC's response to the permanent establishment challenges posed by COVID-19. The presence of individuals in the UK as a consequence of COVID-19 raises questions about whether foreign companies could establish a taxable permanent establishment for UK corporation tax purposes

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