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A company doing business in the UK may initially undertake activities without a taxable presence in the UK.

However, where activities will actually be undertaken in the UK, the parent should consider whether to set up in the UK through a branch (which will usually be treated for tax purposes as a permanent establishment), or a subsidiary.

An overseas company may also acquire a UK permanent establishment without intending to do so. Where the business in the UK develops to the point that the company has a fixed place of business in the UK through which the business of the company is carried on, it will have a permanent establishment. The company may also acquire a UK permanent establishment where it has a UK agent who habitually exercises authority to do business on behalf of the company.

In both cases, care should be taken by overseas companies with operations in the UK, either directly or through an agent, to ensure that those UK operations do not amount to a permanent