Commissionaire meaning

The concept of a ‘permanent establishment’ (PE) The idea of a PE is articulated in Article 5 of the Organisation for Economic Co‑operation and Development (OECD) Model Tax Convention (OECD MTC). Article 5 of the UN Model Tax Convention (UN MTC) adopts a similar, yet broader, approach. In broad terms, a company resident in one territory (the home state) is regarded as having a PE in another (the host state) where it has: a fixed place of business in the host state a dependent agent in the host state acting for it for the UN MTC only, employees or other personnel engaged by the enterprise to deliver services in the host state for periods adding up to six months within any 12‑month period — referred to as a services PE Under Article 7 (Business Profits) of the OECD MTC, the host state may tax the enterprise’s business profits only where they are attributable to a PE located there. Article 7...

For VAT purposes, an intermediary is a person who makes arrangements for, or facilitates, a supply (being the main, or underlying, supply) between two other people. An intermediary can equally be called an agent or a broker, and, particularly in an EU context, a commissionaire. HMRC defines an agent as a person who organises supplies of goods or services between the agent’s customer (that is, the principal) and a third party by: procuring goods or services for the principal (acting as a buying agent), or identifying customers for the principal to sell to (acting as a selling agent) Accordingly, agents are invariably connected with two distinct supplies: the supply of goods or services between their principal and the third party, and the provision of their own agency services to the principal, for which a fee or commission is normally charged The VAT position for supplies made by agents can differ depending on the nature of...

FORTHCOMING CHANGE relating to UK transfer pricing legislation Finance Bill 2026 (as introduced) contains provisions delivering a range of changes to the UK’s transfer pricing legislation. Once enacted, with effect for accounting periods beginning on or after 1 January 2026, the package will, among other matters: remove UK‑to‑UK transfer pricing, subject to carve‑outs intended to prevent opportunities for tax arbitrage amend and clarify the participation condition make clear that the OECD Model Tax Convention and the OECD Transfer Pricing Guidelines are to be used as interpretative aids introduce several amendments to the rules governing financial transactions to better align the UK position with the OECD Transfer Pricing Guidelines Alongside this, the government announced at Budget 2025 that it will proceed with an annual requirement for in‑scope multinationals to report information on cross‑border related party transactions for accounting periods beginning from 1 January 2027; the detailed technical regulations for the new ‘International Controlled Transactions Schedule’ (ICTS) are expected to be published...