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PERMANENT-ESTABLISHMENT


Hybrids and dual inclusion income: are we there yet? premium
Card image Richard Milnes
Card image 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.
17 July 2024
Nomad employees: examining HMRC’s new guidance premium
Card image 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.
14 August 2023
GE Financial, treaty residence, and the meaning of ‘business’ premium
Card image Kyle Rainsford
Kyle Rainsford (Travers Smith) examines the ramifications of the Upper Tribunal’s decision.
26 July 2023
Tax and the City review for July 2023 premium
Card image Zoe Andrews
Card image 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. 
13 July 2023
Tax on establishing a business in Australia
Card image Paula Tallon
Card image 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. 
5 August 2021
International review for May 2021 premium
Card image Tim Sarson
Recent developments that matter from around the globe, reported by Tim Sarson (KPMG).
27 May 2021
International review for February 2021 premium
Card image Tim Sarson
Recent developments that matter from around the globe, reported by Tim Sarson (KPMG).
24 February 2021
International business operating models: the tax issues premium
Card image Gavin Orpwood Louise Keegan Hannah McKenzie
Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the tax risks to international business operating models.
3 December 2020
Tax and the City review for September 2020 premium
Card image Zoe Andrews
Card image Mike Lane
The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
10 September 2020
Fowler: employment or treaty deemed trade? star
Card image Nigel Doran
Nigel Doran (Macfarlanes) examines the recent Supreme Court decision and its ramifications.
1 June 2020
EDITOR'S PICKstar
NEWSRSS Read all
CASESRSS Read all
J Boulting v HMRC
5 November 2025
HMRC v Ducas Ltd
5 November 2025
IN BRIEFRSS Read all
Exclusive purposes
5 November 2025 / Peter Vaines
MOST READ Read all
Tyler Security Ltd v HMRC
29 October 2025
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