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HMRC internal manual

International Manual

HM Revenue & Customs
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Non-residents trading in the UK: Treaty permanent establishment

Fixed place of business permanent establishment - personnel condition

For a fixed place of business to constitute a PE the business of the enterprise must have been carried on through that place, i.e. persons working in the business must have worked from that place. Those persons could be employees, the entrepreneur or proprietor themselves or any other persons receiving instructions from the enterprise e.g.self-employed consultants.