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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: Claimant with an associate outside the UK with a PE in the UK

INTM332650 | Double Taxation applications & claims: permanent establishment and special relationship: Claimant with an associate outside the UK with a PE in the UK

From HM Revenue & Customs · International Manual

Sometimes you may receive a claim where the claimant has an associated company also outside the UK. The associated company could be the parent of the claimant or the claimant could be the parent of the associated company, or they could be inter-related in some other way. It could be that this associated company is trading through a permanent establishment in the UK. This does not deny relief to the claimant company although you need to be sure that the claimant company itself is not trading through its own permanent establishment.

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