Non-resident companies trading through UK permanent establishment
Carrying on a trade in the UK
Commentary –
Tax Reporter ¶764-280
Chargeable gains
Assets ceasing to be chargeable
Commentary –
Tax Reporter ¶592-550
Attribution to UK-resident participators
Commentary –
Tax Reporter ¶592-900
Generally
Commentary –
Tax Reporter ¶591-550
;
Tax Reporter ¶753-250
Corporation tax liability
Commentary –
Tax Reporter ¶764-400
Foreign possessions or investments
Commentary –
Tax Reporter ¶764-400
Generally
Commentary –
Tax Reporter ¶764-260
;
Tax Reporter ¶764-400
Income tax
Commentary –
Tax Reporter ¶764-420
HMRC Guidance –
CTM34220
Interest and royalty payments
Commentary –
Tax Reporter ¶103-855
Leasing mobile drilling rigs/other assets for use on UK Continental Shelf
Commentary –
Tax Reporter ¶764-400
Oil taxation
Commentary –
Tax Reporter ¶798-525
Permanent establishment, meaning
Commentary –
Tax Reporter ¶592-500
;
Tax Reporter ¶764-260
Case Law –
(1) American Foreign Insurance Association v. Davies (H.M. Inspector of Taxes (2) American Foreign Insurance Association v. Commissioners of Inland Revenue (3) American Foreign Insurance Association v. Commissioners of Inland Revenue (4) Davies (H.M. Inspector of Taxes) v. Home Insurance Company (Limited) (5) Davies (H.M. Inspector of Taxes) v. St. Paul Fire & Marine Insurance Company (Limited)
;
Puddu v Doleman (HMIT)
Relevant UK taxes
Commentary –
Tax Reporter ¶700-100
Residence
Commentary –
Tax Reporter ¶764-260
UK representatives
Commentary –
Tax Reporter ¶764-540–Tax Reporter ¶764-600