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Permanent establishment
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Permanent establishment
PERMANENT-ESTABLISHMENT
Taxing cross-border services: time for a Plan B?
Philip Baker KC
Philip Baker KC (Field Court Tax Chambers) considers why existing rules struggle to tax cross-border services effectively and proposes an alternative solution.
Hybrids and dual inclusion income: are we there yet?
Richard Milnes
Fehzaan Ismail
Richard Milnes and Fehzaan Ismail (EY) assess the concept of dual inclusion
income under the UK hybrid provisions following a prolonged period of
iterative change.
Nomad employees: examining HMRC’s new guidance
Martin Shah
Martin Shah (Simmons & Simmons) reviews HMRC’s latest guidance on whether employees of overseas entities working temporarily in the UK give rise to a UK permanent establishment.
GE Financial, treaty residence, and the meaning of ‘business’
Kyle Rainsford
Kyle Rainsford (Travers Smith) examines the ramifications of the Upper Tribunal’s decision.
Tax and the City review for July 2023
Zoe Andrews
Mike Lane
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the Court of Appeal decisions in Royal Bank of Canada and Civic Environmental Systems and the consultation on transfer pricing, DPT and permanent establishment.
Tax on establishing a business in Australia
Paula Tallon
Siobhan Sellick
Now that Australia and UK have signed their trade agreement, Paula Tallon and Siobhan Sellick (Prosperity Advisers Group) explain what Australian taxes UK companies will encounter when establishing a business presence there.
International review for May 2021
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
International review for February 2021
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
International business operating models: the tax issues
Gavin Orpwood
Louise Keegan
Hannah McKenzie
Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the
tax risks to international business operating models.
Tax and the City review for September 2020
Zoe Andrews
Mike Lane
The latest developments that matter, reviewed by Mike Lane and
Zoe Andrews (Slaughter and May).
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4
EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
NEWS
Read all
Budget capital allowances changes: mixed picture for business investment decisions
Government declines to expand land remediation relief
HMRC publish new RTI guidance for employers
ERS: annual returns after scheme closure
CBAM: technical guidance on emissions reporting
CASES
Read all
Abbey Group Ltd v HMRC
Strauss Phillips & Co Ltd v HMRC
Education Training Collective v HMRC
Other cases that caught our eye: 30 October 2026
ScottishPower (SCPL) Ltd and others v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
The Nigel Blackwell Family Trust and others v HMRC
One minute with... Helen Miller
Chancellor reportedly rejects alignment of CGT and income tax rates
ScottishPower (SCPL) Ltd and others v HMRC
Side-by-Side: four scenarios for 2030