| 释义 |
permanent establishment
A company resident in the UK is subject to UK tax on its worldwide profits. A company not resident in the UK is subject to UK tax on the profits of a “permanent establishment” in the UK. This provision is, generally, copied in double tax agreements. The Corporation Tax Act 2010 s 1141 uses the definition in the model double tax agreement drawn up by the Organization for Economic Cooperation and Development, a permanent establishment being defined as a “fixed place of business through which the business of an enterprise is wholly or partly carried on”. The definition goes on to state specifically that the term “permanent establishment” includes a place of management, branch, office, factory, workshop, exploration base, mine, oil or gas well, quarry, or building site. See also double taxation relief. |