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HMRC internal manual

International Manual

Non-residents trading in the UK: permanent establishment: domestic and treaty law: fixed place of business: places especially included within the definition of permanent establishment

Fixed place of business permanent establishment - places especially included within the definition of permanent establishment

The model treaty at Article 5(2) and domestic law at CTA2010/S1141(2) give some specific examples of what is “especially included” in the term permanent establishment these are listed in INTM264300  The two lists are virtually identical.

Neither is an exhaustive list of the places that could be a permanent establishment. Furthermore, it is clear from the Commentary in order for any of these places to constitute a permanent establishment they would also need to have the general attributes of a fixed place of business, i.e. the geographic, period of duration and personnel conditions must be met.