HMRC has published new guidance providing a number of examples involving employees of overseas entities working temporarily in the UK and considering whether the permanence condition of the fixed place of business permanent establishment (PE) test might be met in those scenarios. Whilst a welcome development, the guidance published in the International Manual at INTM264435 is ultimately limited in scope and businesses with employees working occasionally in the UK may still need to consider their position on a case by case basis. In addition, even where a fixed place of business PE is not established, the position regarding dependent agent PEs will separately need to be considered.
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HMRC has published new guidance providing a number of examples involving employees of overseas entities working temporarily in the UK and considering whether the permanence condition of the fixed place of business permanent establishment (PE) test might be met in those scenarios. Whilst a welcome development, the guidance published in the International Manual at INTM264435 is ultimately limited in scope and businesses with employees working occasionally in the UK may still need to consider their position on a case by case basis. In addition, even where a fixed place of business PE is not established, the position regarding dependent agent PEs will separately need to be considered.
If you are not a subscriber, subscribe now to read this content.
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