Jurisdiction(s):
United Kingdom

Key definition

Rules definition

What does Rules mean? Rules describes the written provisions that govern how a pension scheme operates—especially occupational pension schemes—usually contained in, or annexed to, the trust deed (trust deed and rules). Legislation refers to these as scheme rules (for example, Pensions Act 1995 and Pensions Act 2004 in the UK, and the Pensions Act 1990 in Ireland). Scheme rules set out eligibility, benefit structure (defined benefit or defined contribution), contributions, service and accrual, retirement options and ages, revaluation/indexation, ill‑health and death benefits, transfers in and out, leaver provisions, forfeiture, augmentation, priority on winding‑up, discretions and decision‑making, and the scheme’s amendment and termination powers. They also...

UK taxation of non-UK resident companies: permanent establishments, UK property income and gains, continental shelf oil and gas, income tax, DPT/UTPP, and double tax treaties

Published by a LexisNexis Tax expert

Practice notes

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Section 49 and Schedule 7 of the Finance Act 2026 amend the UK’s domestic legislation concerning UK permanent establishments of non-UK companies, taking effect for accounting periods (in respect of corporation tax) or tax years (for income tax) that begin on or after 1 January 2026, respectively. In each case, the measures adjust both the definition of a UK permanent establishment and the rules for attributing profits to a UK permanent establishment, so as to bring them nearer into line with the OECD Model Tax Convention, from that date and thereafter in UK law.

Section 46 and Schedule 5 of the Finance Act 2026 provide for the abolition of the DPT regime and its replacement by the ‘unassessed transfer pricing profits’ (UTPP) rules, effective for accounting periods commencing on or after 1 January 2026. HMRC has inserted a new chapter within the HMRC International Manual containing guidance on the UTPP rules at INTM489100. For more information about these changes, see News Analysis: Budget 2025—Tax analysis — International...

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Web page updated on 22/05/2026

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