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/S107contains 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.