This content covers guidance applicable to the coronavirus (COVID-19) pandemic.
The increase in the number of employees working from home during the coronavirus pandemic could lead to a risk of creating unintended permanent establishments in the UK and in other countries. This will be relevant where the employee is located in a different country to their employer and will be of particular concern where the employee has a senior role and / or enters into contracts on behalf of the non-resident employer.
In the UK, if a non-resident company is treated as trading through a UK permanent establishment (PE), all of its income and gains from the PE would be brought within the charge to UK corporation tax1. In addition, the UK resident individual would likely be
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 17:34