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A UK company expanding overseas may do so in a variety of ways, including:

1. •

   distance trading from the UK, with no local presence

2. •

   a branch, which can be formed with just one employee working from home

3. •

   a fully established local subsidiary

The decision to trade in another jurisdiction involves a number of considerations, both commercial and tax-related. Some of the key tax issues include whether the activities constitute a permanent establishment and how the overseas activities should be structured. It is important, at the outset, that advice is taken by the company, not only in relation to tax, but on the wider business implications.

The tax position of the UK company overseas will depend on the extent to which the company does business in the jurisdiction and the choice of overseas entity from which to carry on the business.

In most cases, establishing the overseas operation will involve a choice between running the business as a branch or via a local subsidiary. There are a number of commercial and tax