Jurisdiction(s):
United Kingdom

UK taxation of non-UK resident companies: checklist on permanent establishments, property, income and gains, VAT, stamp, employment and sector-specific taxes (including Finance Act 2026 changes)

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Section 49 together with Schedule 7 to the Finance Act 2026 revises the UK’s domestic rules concerning UK permanent establishments of overseas, non-UK companies, applying for accounting periods (for corporation tax) or tax years (for income tax) that start on or after 1 January 2026.

These measures update both the meaning of a UK permanent establishment and the framework for attributing profits to such establishments so as, in each instance, to align them more closely with the OECD Model Tax Convention. This ensures the domestic position is more consistent with internationally accepted norms.

Separately, Section 46 and Schedule 5 to the Finance Act 2026 scrap the DPT regime and introduce the ‘unassessed transfer pricing profits’ (UTPP) provisions, effective for accounting periods commencing on or after 1 January 2026.

HMRC has published a new chapter in the International Manual setting out guidance on the UTPP rules at INTM489100. Additional practical guidance is provided there.

For further detail on these updates, see News Analysis: Budget 2025—Tax analysis — International.

This document summarises the questions that a non-UK resident company ought to examine when assessing whether it will be liable to pay tax in the UK...

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Web page updated on 20/05/2026

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