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Permanent establishments of non-resident companies

Category Technical Articles
AuthorTechnical Department
Article by Arthur Sellwood, former Inspector of Taxes, which appeared in the May 2004 issue of Tax Adviser. To download the article in Adobe (pdf) format, please click on the link below. KEY POINTS

  • An old practice newly defined
  • Relevant only for companies and corporation tax
  • Important for double taxation treaties
  • No time requirement specified for the permanence of sites and constructions
  • New rules for computation

Technical Department
020 7235 9381

May 2004 by Arthur Sellwood

 

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