Companies: UK residence and permanent establishments | Practical Law
This note details the UK corporate residence rules and explains how to determine whether a company is resident in the UK for UK tax purposes. It also describes the rules that determine whether a non-UK resident company has a UK permanent establishment and how UK permanent establishments are taxed under UK law. In addition, this note describes how the right to tax a company's profits may be divided under a double tax treaty if that company is resident in two territories or is resident in one territory but has a permanent establishment in another territory.