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HMRC internal manual

International Exchange of Information Manual

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Action 5 rulings: Types of rulings to exchange: Rulings relating to permanent establishments

IEIM541300: Action 5 rulings: Types of rulings to exchange: Rulings relating to permanent establishments

Rulings related to permanent establishments are automatically exchanged with relevant jurisdictions under Action 5.  The rules apply equally to situations where the permanent establishment is in the UK, and where there is an overseas permanent establishment of a UK company.

The ruling may either:

  • Relate to the existence or absence of a permanent establishment (IEIM541310)
  • Provide for the attribution of income or profit between parts of a business enterprise which operates in more than one country, where questions may arise as to the taxable income to be recognised in any such part (IEIM541320)

 

Rulings relating to permanent establishments must also be exchanged under the DAC (IEIM550010).