[INTM264300] Non-residents trading in the UK: permanent establishment: domestic and treaty law: permanent establishment definition
Below is a description of the domestic and treaty definition of Permanent Establishment.
As you will see there are two broad circumstances within which a non-UK resident or a UK resident enterprise could have a permanent establishment. These are:
•Where there is a fixed place of business through which the business of an enterprise is wholly or partly carried on – Model Treaty Article 5(1). This is known as the fixed place of business permanent establishment (INTM264400).