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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/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.