UK Legislation

S5 and S19 CTA 2009 introduce the concept of Permanent Establishment (‘PE’) and cover the corporation tax charging provisions (see INTM262300).

S1141 et seq. CTA 2010 cover the UK definition of PE. That definition of PE is similar to, and has the same broad effect as, the OECD model treaty article 5 definition.

With effect from accounting periods beginning on or after 1 January 2003, for companies only, the term ‘branch or agency’ was replaced by the term ‘permanent establishment’.

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