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HMRC internal manual

International Manual

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DT Agreements: Australia - Income from a UK source paid to a resident of Australia

Construction Industry Scheme: Permanent establishment provisions

From 1 July 2004: Article 5 of the 2003 Convention

The permanent establishment provisions of Article 5 include references to a building siteor construction or installation project. This provides that where such a site continuesfor a period of more than twelve months it will constitute a permanent establishment.

Before 1 July 2004: Article 4 of the 1968 Agreement

The permanent establishment provisions of Article 5 include references to a building siteor a construction, installation or assembly project. This provides that where such a sitecontinues for a period of more than six months it will constitute a permanentestablishment.