Income Tax Act 2007 section 286A

The UK permanent establishment requirement

Section 286A sets out the requirement that a relevant company must maintain a permanent establishment in the United Kingdom at all times from the date the relevant holding is issued.

• The relevant company must have a permanent establishment in the UK.
• This requirement applies from the date the relevant holding is issued onwards.
• The permanent establishment must be maintained continuously, with no gaps, up to the point in time being considered.
• If the company ceases to have a UK permanent establishment at any point after the holding is issued, the requirement is not met.