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HMRC internal manual

Capital Gains Manual

Non-resident company with a UK permanent establishment: obtaining advice

Where it is necessary to make submissions to a specialist office on points of doubt or difficulty involving chargeable gains arising to companies trading in the UK through a permanent establishment the problem

  • may relate to whether the activity is a trade carried on in the UK through a permanent establishment, or
  • may concern how the chargeable gains legislation operates once it is accepted that the activity is a trade carried on in the UK through a permanent establishment.

If the problem relates to the first of these possibilities the submission should be sent to Business International, Transfer Pricing Team. If it relates to the second possibility the submission should be sent to Capital Gains Technical Group. Where both problems are involved appropriate submissions should be made to both specialists.