INTM332630 | Double Taxation applications & claims: permanent establishment and special relationship: What the PE provisions are

From HM Revenue & Customs · International Manual

You will have to consider whether the Permanent Establishment condition is satisfied when you give relief under DTAs. Many articles in the DTAs do not allow relief where

  • the claimant has a Permanent Establishment in the UK

or

  • the income on the claim is connected with the Permanent Establishment.