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Official guidance
International Manual

INTM332600 · Double Taxation applications & claims: permanent establishment and special relationship

  • INTM332610 · What a permanent establishment is
  • INTM332620 · When you have to consider PE
  • INTM332630 · What the PE provisions are
  • INTM332640 · How you know the PE condition is satisfied
  • INTM332650 · Claimant with an associate outside the UK with a PE in the UK
  • INTM332660 · Claimant is a subsidiary of UK company: Claimant which is a subsidiary of a UK company
  • INTM332670 · What Special Relationship is
  • INTM332680 · How you recognise the ‘Special Relationship’ condition
  • INTM332690 · When special relationship condition satisfied: How you know the special relationship condition is satisfied
  1. Double Taxation applications & claims: permanent establishment and special relationship: contents
  2. Double Taxation applications & claims: permanent establishment and special relationship: What the PE provisions are

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.

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