PERMANENT-ESTABLISHMENT

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.

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.

Kyle Rainsford (Travers Smith) examines the ramifications of the Upper Tribunal’s decision.

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. 

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. 

Recent developments that matter from around the globe, reported by Tim Sarson (KPMG).

Recent developments that matter from around the globe, reported by Tim Sarson (KPMG).

Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the tax risks to international business operating models.

The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).