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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Non-residents: UK income: Subsidiary and associated companies

A subsidiary or an associated company, being an independent legal entity, is not a permanent establishment of its parent or other associated companies, unless exceptionally it acts in relation to the parent or other associated company as a dependent agent (see DT1713). Dependent or independent status does not turn on the shareholding relationship between principal and agent. The fact that an agent is a subsidiary company does not alone make it a dependent agent and an agent unconnected with the enterprise may nevertheless be a dependent agent. Generally however, this is a difficult area and the advice of International Division, Business Tax Group should be sought if an agent who is not clearly a broker or general commission agent claims to be an agent of independent status.