– see also Foreign branches of UK companies; Non-resident companies trading through UK permanent establishment; Foreign permanent establishments

Access to treat benefits

Commentary – Schwarz on Tax Treaties 7.04

Agency law, civil and common law

Commentary – Schwarz on Tax Treaties 7.09

Agency permanent establishment

Commentary – Schwarz on Tax Treaties 7.09

Agent of independent status

Legislation/Regulatory – CTA2010 s. 1142

Agents, independent

Commentary – Schwarz on Tax Treaties 7.03

Allocation of profits

Commentary – Schwarz on Tax Treaties 7.02

Alternative finance arrangements

Commentary – Schwarz on Tax Treaties 7.10

Alternative finance returns

Legislation/Regulatory – CTA2010 s. 1144

Anti-fragmentation

Commentary – Schwarz on Tax Treaties 7.13

At the disposal of the enterprise

Commentary – Schwarz on Tax Treaties 7.04–Schwarz on Tax Treaties 7.05

Attribution of interest

Commentary – Schwarz on Tax Treaties 10.04

Attribution of investment income

Commentary – Schwarz on Tax Treaties 4.08

Attribution of profits to

Commentary – Schwarz on Tax Treaties 9.04

Auxiliary activities

Anti-fragmentation

Commentary – Schwarz on Tax Treaties 7.13

Branch

Commentary – Schwarz on Tax Treaties 7.06–Schwarz on Tax Treaties 7.07

Brokers

Commentary – Schwarz on Tax Treaties 7.10

Building or construction sites

Commentary – Schwarz on Tax Treaties 7.08

Business, carrying on of

Commentary – Schwarz on Tax Treaties 7.04Schwarz on Tax Treaties 9.02

Capital assets

Commentary – Schwarz on Tax Treaties 12.05

Closely related person

Commentary – Schwarz on Tax Treaties 10.04

Commissionaire

Commentary – Schwarz on Tax Treaties 7.09Schwarz on Tax Treaties 18.05

Cross-border business taxation

Commentary – Schwarz on Tax Treaties 7.02

Deemed activity

Commentary – Schwarz on Tax Treaties 7.12

Deemed, illustrative list

Commentary – Schwarz on Tax Treaties 7.06

Digital economy

Commentary – Schwarz on Tax Treaties 7.05

Discrimination

Commentary – Schwarz on Tax Treaties 9.02

Discriminatory treaties in EU law

Commentary – Schwarz on Tax Treaties 3.06

Diverted profits tax

Commentary – Schwarz on Tax Treaties 7.15

Dividends connected with

Commentary – Schwarz on Tax Treaties 7.15

Double taxation relief

Commentary – Tax Reporter ¶170-600
HMRC Guidance – INTM153060

Employment income

Commentary – Schwarz on Tax Treaties 7.02

Enterprise investment scheme

Legislation/Regulatory – ITA2007 s. 180A, 191A, 1007A

Enterprise investment scheme requirement

Commentary – Tax Reporter ¶323-315

Enterprise management incentives

Commentary – Tax Reporter ¶466-190
Legislation/Regulatory – ITEPA2003 Sch. 5, para. 14A

Exclusions

Commentary – Schwarz on Tax Treaties 7.02Schwarz on Tax Treaties 7.10Schwarz on Tax Treaties 7.13Schwarz on Tax Treaties 7.15

Existence of, overseas

Commentary – 10.2

Existence, elements to be met

Commentary – Schwarz on Tax Treaties 7.04

Fixed place

Commentary – Schwarz on Tax Treaties 7.13

Fixed place of business, meaning

Legislation/Regulatory – CTA2010 s. 1141

Foreign permanent establishment

– see Foreign permanent establishments

Furnishing of services

Commentary – Schwarz on Tax Treaties 7.06

General commission agent

Commentary – Schwarz on Tax Treaties 7.10

Generally

Commentary – 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)

Geostationary satellite

Commentary – Schwarz on Tax Treaties 5.03

Habitual exercise of authority

Commentary – Schwarz on Tax Treaties 7.09

Illustrative list

Commentary – Schwarz on Tax Treaties 7.06

Independent agents

Commentary – Schwarz on Tax Treaties 7.10

Independent brokers

Legislation/Regulatory – CTA2010 s. 1145

Independent investment managers

Legislation/Regulatory – CTA2010 s. 1146-1150, 1152

Installation projects

Commentary – Schwarz on Tax Treaties 7.08

Insurance business

Commentary – Schwarz on Tax Treaties 7.12

Interest

Attributed to

Commentary – Schwarz on Tax Treaties 10.04

In third states

Commentary – Schwarz on Tax Treaties 10.04

Interest and royalties directive

Commentary – Schwarz on Tax Treaties 14.07

Interpretation

Commentary – Schwarz on Tax Treaties 7.03

Investment managers

Commentary – Schwarz on Tax Treaties 7.10

Lloyd's agents

Legislation/Regulatory – CTA2010 s. 1151

Lloyd's members' agents

Commentary – Schwarz on Tax Treaties 7.10

Meaning

Commentary – Schwarz on Tax Treaties 7.02
Legislation/Regulatory – CTA2010 s. 1141

Member States

Associated enterprises, attribution of profits

Legislation/Regulatory – Conv. 90/436

Transfer

Legislation/Regulatory – Dir. 2009/133 art. 10

Mergers directive

Commentary – Schwarz on Tax Treaties 14.09

Negotiation of contracts

Commentary – Schwarz on Tax Treaties 7.13

News agency

Commentary – Schwarz on Tax Treaties 7.02

Non-discrimination

Commentary – Schwarz on Tax Treaties 9.02

Non-resident companies

– see Non-resident companies

Non-resident company trading through UK representative

Determination

Legislation/Regulatory – CTA2010 s. 969

Interpretation

Legislation/Regulatory – CTA2010 s. 972

Obligations and liabilities

Legislation/Regulatory – CTA2010 s. 970, 971

Non-residents with

Corporation tax, limits on/reduction of credit relief

Legislation/Regulatory – TIOPA2010 s. 43

Unilateral relief

Legislation/Regulatory – TIOPA2010 s. 30

Offshore exploration and exploitation activities

Business profits

Commentary – Schwarz on Tax Treaties 13.04

Employment income

Commentary – Schwarz on Tax Treaties 13.04

Generally

Commentary – Schwarz on Tax Treaties 13.04

Parent companies and subsidiaries

Commentary – Schwarz on Tax Treaties 7.14

Parent-Subsidiary Directive

Commentary – Schwarz on Tax Treaties 14.06

Partnership

Commentary – Schwarz on Tax Treaties 7.04Schwarz on Tax Treaties 7.07Schwarz on Tax Treaties 7.09

Permanence

Commentary – Schwarz on Tax Treaties 7.04

Physical

Commentary – Schwarz on Tax Treaties 7.04

Place of business

Commentary – Schwarz on Tax Treaties 7.02Schwarz on Tax Treaties 7.04Schwarz on Tax Treaties 7.07

Preparatory or auxiliary activities

Commentary – Schwarz on Tax Treaties 7.13
Legislation/Regulatory – CTA2010 s. 1143

Profits of

– see Business profits

Regular agency

Commentary – Schwarz on Tax Treaties 7.09

Royalties connected with

Commentary – Schwarz on Tax Treaties 10.05

Secondment arrangements

Commentary – Schwarz on Tax Treaties 7.11

Seed enterprise investment scheme

Commentary – Tax Reporter ¶320-150

Services permanent establishment

Commentary – Schwarz on Tax Treaties 7.11–Schwarz on Tax Treaties 7.12

Soliciting orders

Commentary – Schwarz on Tax Treaties 7.04Schwarz on Tax Treaties 7.06Schwarz on Tax Treaties 7.09

Splitting up of contracts

Commentary – Schwarz on Tax Treaties 18.05

Storage display or delivery of goods

Commentary – Schwarz on Tax Treaties 7.13

Subsidiary as permanent establishment

Commentary – Schwarz on Tax Treaties 7.06Schwarz on Tax Treaties 7.09Schwarz on Tax Treaties 7.11

Tax consequences

Commentary – Schwarz on Tax Treaties 14.09

Term

Commentary – Schwarz on Tax Treaties 7.02Schwarz on Tax Treaties 7.04

Third states

Interests

Commentary – Schwarz on Tax Treaties 10.04

Investment income

Commentary – Schwarz on Tax Treaties 10.04

Royalties

Commentary – Schwarz on Tax Treaties 10.05

Transfer of

Legislation/Regulatory – Dir. 2009/133 art. 10

Transfer of, EC mergers directive

Commentary – Tax Reporter ¶103-840

Treaty provisions

Commentary – 10.5.2

UK domestic rules

Commentary – 10.5.1

Unconventional

Commentary – Schwarz on Tax Treaties 7.12

Venture capital trust requirement

Commentary – Tax Reporter ¶326-400
HMRC Guidance – VCM55040

Venture capital trusts

Legislation/Regulatory – ITA2007 s. 286A, 302A, 1007A