Tag Archives: UK Residence

COVID-19 Impact: UK Corporate Residence & Permanent Establishment

By Sam Pearse

16.04.2020

Summary

  • The OECD and HMRC have issued guidance on the impact of Covid-19 on corporate residence and permanent establishment.
  • Both have expressed sympathy and understanding, and intimated that the restrictions caused by Covid-19 will not have an impact on assessment.

Introduction

The travel restrictions imposed as a result of trying to control the spread of Covid-19 present myriad issues for corporate groups. Two such problems are the impact on the corporate residence of a company and whether a permanent establishment in the UK could be unwittingly created.

Her Majesty’s Revenue and Customs (HMRC) and the Organisation for Economic Co-operation and Development (OECD) have published guidance setting out their views on the impact of travel restrictions.

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