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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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Double Taxation applications & claims: permanent establishment and special relationship: What the PE provisions are

You will have to consider whether the Permanent Establishment condition is satisfied when you give relief under DTAs. Many articles in the DTAs do not allow relief where

  • the claimant has a Permanent Establishment in the UK

or

  • the income on the claim is connected with the Permanent Establishment.