Company A is an online retail business registered in Mauritius. Its top management are based in Ghana and the USA. Its customers are mainly in Ghana, Kenya and Uganda, none in the UK. The customers order goods from the companies' website and pay in local currencies. The goods are procured all around the world including UK. The goods from UK suppliers are processed and shipped abroad to its customers from a rented office in London. The staff are agency staff. The business also rent a small office in London.
Based on this information will the company be liable to corporate tax from a permanent establishment point of view.
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