Policy paper
Reform of the foreign permanent establishment exemption
This measure reforms the taxation of foreign permanent establishments, making the elective exemption regime that applies to their profits and losses mandatory for Corporation Tax.
Documents
PDF, 485 KB, 15 pages
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Details
This measure reforms the taxation of foreign permanent establishments, making the elective exemption regime that applies to their profits and losses mandatory for Corporation Tax.
This page includes draft legislation for consultation, as well as accompanying documents.
If you would like to respond to this consultation, you should email foreignpepolicy@hmrc.gov.uk by 13 September 2026.
Updates to this page
Published 13 July 2026