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HMRC internal manual

International Manual

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

Construction Industry Scheme: Permanent establishment provisions

From 6 April 2003: Article 5 of the 2002 convention

The permanent establishment provisions of Article 5 include references to a buildingsite, a construction, assembly or installation project or any supervisory activity inconnection with such site or project. This provides that where such a site or activitycontinues for a period of more than twelve months it will constitute a permanentestablishment.

Before 6 April 2003: Article 4 of the 1969 Convention

The permanent establishment provisions of Article 4 of the 1969 Convention includereferences to a building site or construction or assembly project. This provides thatwhere such a site continued for a period of more than twelve months it constituted apermanent establishment.