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HMRC internal manual

International Manual

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

Construction Industry Scheme: Permanent establishment provisions

Article 5 of the Convention

The permanent establishment provisions of article 5 include references to a buildingsite, construction or assembly project. This provides that where such a site or projectcontinues for a period of more than twelve months it will constitute a permanentestablishment.