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UK Changes Definition of Permanent Establishment
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Trade Publication Article
UK Changes Definition of Permanent Establishment
2019
Overview
The changes to the definition or permanent establishment (PE) in Great Britain is discussed. The British Finance Act 2019 includes the legislation required to update domestic law to align with the country's position on changes to the PE definition arising from the OECD's Base Erosion and Profit Shifting (BEPS) project and included within the Multilateral Instrument. This effectively expands the definition of PE in the country which together with forthcoming changes to many double tax treaties is likely to result in additional PE. The BEPS project included a workstream focused on reviewing the PE threshold to address situations where taxpayers were setting up arrangements seen as intended to avoid having a PE. In order to adopt the proposed changes to the PE definition from Action 7, changes to double tax treaties, as well as domestic law changes, would be required.
Publisher
Thomson Reuters (Tax & Accounting) Inc
