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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Non-residents: UK income: Business Profits

Where it is established that a non-resident enterprise is trading in the United Kingdom through a branch or agency and that the branch or agency is a permanent establishment of the enterprise, the business profits Article in an agreement sets out the rules for taxing the profits of the enterprise. These are described in the following paragraphs.