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Permanent establishment
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Permanent establishment
PERMANENT-ESTABLISHMENT
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
Mike Lane
Zoe Andrews
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
Hannah McKenzie
Gavin Orpwood
Louise Keegan
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
Mike Lane
Zoe Andrews
The latest developments that matter, reviewed by Mike Lane and
Zoe Andrews (Slaughter and May).
Fowler: employment or treaty deemed trade?
Nigel Doran
Nigel Doran (Macfarlanes) examines the recent Supreme Court decision and its ramifications.
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EDITOR'S PICK
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
1 /7
Medpro: better late than never
Stacey Cranmore
2 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
3 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
4 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
5 /7
Understanding the FIG regime
Jo Bateson
6 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
7 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
NEWS
Read all
HMRC manual changes: 21 November 2025
Tax stability key for internationally mobile individuals
HMRC campaign on management expenses
Partnership NICs potentially scrapped, but concerns remain
Set tax thresholds at real values, says IFS
CASES
Read all
HMRC v Moir Management Services Ltd
1st Alternative Medical Staffing Ltd v HMRC
J Dreyer v HMRC
Other cases that caught our eye: 21 November 2025
Saunders v HMRC
IN BRIEF
Read all
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
Yet more Budget speculation
Fixing the FIG regime before extending it
The new non-dom rules
MOST READ
Read all
Yet more Budget speculation
Meet in the middle: HMRC’s transfer pricing settlement policy
TSI Instruments Ltd v HMRC
Saunders v HMRC
The new non-dom rules