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UK tax weekly (28 May 2026): mandatory foreign permanent establishment exemption; Re Waldorf cram down; temporary 5% VAT for children’s meals/attractions; key cases and HMRC guidance updates

Published on: 28 May 2026

Published by a LexisNexis Tax expert
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International

UK government announces mandatory application of the foreign permanent establishment exemption

On 21 May 2026, the government released a policy paper outlining reforms to the taxation of UK-resident companies operating partly through foreign permanent establishments (PEs), making the foreign PE exemption compulsory for most businesses for accounting periods starting on or after 1 January 2027. For UK-resident companies with foreign PEs involved in activities relating to the exploration or exploitation of oil and gas, the measure will take effect from 1 September 2026. This is achieved by deeming those companies’ accounting periods to end on 31 August 2026, with the new rules applying from the next day. The policy paper indicates the reform is intended to stop losses arising in foreign PEs from being used to shelter UK profits from tax, while keeping the regime internationally competitive. The changes will be accompanied by an anti-avoidance rule aimed at preventing arrangements that would seek to artificially accelerate the...

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