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HMRC internal manual

International Manual

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

Construction Industry Scheme: Permanent establishment provisions

Article 5 of the 1978 Convention

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