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HMRC internal manual

International Manual

Double Taxation applications & claims: permanent establishment and special relationship: Claimant with an associate outside the UK with a PE in the UK

Sometimes you may receive a claim where the claimant has an associated company also outside the UK. The associated company could be the parent of the claimant or the claimant could be the parent of the associated company, or they could be inter-related in some other way. It could be that this associated company is trading through a permanent establishment in the UK. This does not deny relief to the claimant company although you need to be sure that the claimant company itself is not trading through its own permanent establishment.