Jurisdiction(s):
United Kingdom

Key definition

UK permanent establishment definition

What does UK permanent establishment mean? In practice, a UK permanent establishment describes when a non‑UK resident company has a sufficiently fixed UK business presence, or a dependent agent here, so that part of its business is treated as carried on in the UK for corporation tax purposes. UK tax legislation (CTA 2009) defines a permanent establishment as either: (1) a fixed place of business in the UK through which the company’s business is wholly or partly carried on (for example, a place of management, branch, office, factory, workshop or certain resource‑extraction sites); or (2) a person acting on its behalf who has, and...

UK property: permanent establishment rules for non-UK companies—definition, examples, treaty interaction, building site thresholds, and impact of 2016-2020 reforms, with Finance Act 2026 update

Published by a LexisNexis Tax expert

Practice notes

Stop Press: Section 49 of, and Schedule 7 to, the Finance Act 2026 amends the UK’s domestic legislation in relation to uk permanent establishments of non-UK companies, with effect for accounting periods (in the case of corporation tax) or tax years (in the case of income tax) beginning on or after 1 January 2026

These measures update the meaning of a UK permanent establishment and the framework for allocating profits to a UK permanent establishment, in each case to achieve closer alignment with the OECD Model Tax Convention. They also refine how the investment manager exemption applies in practice and operates. For more information and analysis, see News Analysis: Budget 2025—Tax analysis — International. This Practice Note explores what constitutes a UK permanent establishment (PE) in the specific context of UK real estate...

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Charles Goddard

Rosetta Tax

Charles is a solicitor at Rosetta Tax Limited, which specialises in corporate tax advice to businesses and professional services firms. He has a broad range of tax advisory expertise, having acted for a variety of UK-based and international financial institutions and listed companies. He has particular expertise in the real estate and finance sectors, with a strong focus on the taxation of insolvency and restructuring transactions.Charles was for six years until 2012 a tax partner at Berwin Leighton Paisner LLP. Prior to joining BLP, he spent eight years at Slaughter and May as a trainee and associate in their Tax group. He is recommended by both Chambers and Partners and Legal 500....

Web page updated on 22/05/2026

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