As many governments face significant financial deficits, taxpayers are seeing an increase in efforts by fiscal authorities to tax the activities of foreign companies in their jurisdiction. Expanding the definition of what is considered a permanent establishment of a foreign company is part of this trend.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap