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Where Taxpayers and Advisers Meet

Foreign companies and permanent establishment in UK

Asvsix
Posts:38
Joined:Wed Aug 06, 2008 4:00 pm
Foreign companies and permanent establishment in UK

Postby Asvsix » Mon Apr 23, 2018 6:19 pm

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.

GlobalTaxAdviser
Posts:633
Joined:Fri Dec 05, 2014 1:18 am

Re: Foreign companies and permanent establishment in UK

Postby GlobalTaxAdviser » Tue Apr 24, 2018 10:17 am

I assumed you have looked at the double tax treaty ?

While the company may have a fixed permanent establishment in the UK with the rented office

With the place of effective management overseas - the primary taxing rights would be in either Ghana or USA.

Kind Regards

GTA

Asvsix
Posts:38
Joined:Wed Aug 06, 2008 4:00 pm

Re: Foreign companies and permanent establishment in UK

Postby Asvsix » Tue Apr 24, 2018 10:43 am

GTA, thank you for your reply. Yes i have considered the double tax treaty.


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