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HMRC internal manual

Company Taxation Manual

Groups: group relief: the international aspect -permanent establishments


A non-resident company that carries on a trade in the UK through a permanent establishment is within the charge to CT and so can claim and surrender group relief (CTM80150).

CTA10/S107 contains special rules for determining the amount, if any, that can be surrendered. There is guidance on these rules at CTM80310.

For companies resident in the UK trading overseas through a permanent establishment, there are also special rules. There is guidance on these rules at CTM80350.