WebGenerally services are treated in the same way as other types of business activities, that is the combined effect of Article 5 and 7 is such that profits from services performed in the UK by a non-resident are not taxable if they are not attributable to a permanent establishment. Alternative provision The OECD Commentary to Article 5 states that: WebIntroduction Below is a description of the domestic and treaty definition of Permanent Establishment. As you will see there are two broad circumstances within which a non-UK …

NO Yes YES - HM Revenue and Customs

WebThis publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital.This full version contains the full text of the Model Tax Convention as it read on 21 November 2024, including the Articles, Commentaries, non-member economies’ positions, the Recommendation of the OECD Council, the historical notes … WebGenerally services are treated in the same way as other types of business activities, that is the combined effect of Article 5 and 7 is such that profits from services performed in the … contact shell face ansys

[INTM264300] INTM264300 – Non-residents trading in the UK: …

WebINTM264000 – Non-residents trading in the UK: permanent establishment: domestic and treaty law [INTM264000] INTM264400 – Non-residents trading in the UK: permanent establishment: domestic and treaty law: fixed place of business [INTM264400] WebINTM264000: permanent establishment: domestic and treaty law; INTM267000: Profits of the PE; INTM268000: ‘Machinery’ provisions for assessment and collection via UK representatives; INTM269000: Transactions carried out through UK investment managers, brokers or Lloyds agents: contents; INTM269500: Investment from abroad: Inward … WebINTM264000. permanent establishment: domestic and treaty law: Contents. INTM267000. Profits of the PE: contents. INTM268000 'Machinery' provisions for assessment and … contact shein.com