Finance Act 2015

Section 86 of the legislation can apply where foreign companies make substantial sales through activity in the UK while avoiding the creation of a UK permanent establishment (PE). Such arrangements are often combined with other arrangements that allow the foreign company to transfer profits associated with those sales to companies resident in territories where little or no tax is paid. (These arrangements are sometimes given names such as ‘double Irish’ in the press and tax publications, but there are many variations.)

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