Trading in the UK through a PE

Following the recent sessions of the Public Accounts Committee with Google and HMRC many commentators seem to remain unconvinced that US-based multinationals with UK operations can legitimately claim not to be taxable in the UK on the full amount of their UK sales. The committee itself was clearly puzzled that evidence given to it by ‘whistleblowers’ did not obviously undermine Google’s own position and left with the feeling that HMRC was missing a trick. Countering suggestions that the committee did not understand the underlying tax principles well enough its chair Margaret Hodge MP has insisted that tax professionals cannot simply stand on the sidelines and criticise others for not understanding the...