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HMRC internal manual

Oil Taxation Manual

Non-Residents Working on the UK Continental Shelf: Double Taxation Agreements - Long term offshore construction type work - Overview

The provisions of a Permanent Establishment Article may effect the charge to UK tax under CTA09\S1313 on profits arising to, say, a foreign company performing a long-term contract for the fabrication of a platform in the UKCS using a construction vessel stationed at the construction site. There are several questions to consider:

  • Is there a fixed place of business (see OT41642)?
  • Is it listed in Article 5 as an example of a permanent establishment (see OT41643)?
  • Is there a construction project lasting more than a designated number of months (see OT41644)?