Expert guidance for businesses with UK operations

If your business operates in the UK through an overseas company, it is crucial to understand whether your activities create a “permanent establishment” (PE) under UK tax rules. A UK PE may give rise to Corporation Tax obligations and require registration and reporting to HMRC.

Our Expertise

A permanent establishment generally arises when a company has a fixed place of business in the UK, or when an agent in the UK habitually exercises authority to do business on the company’s behalf. This could include an office, branch, workshop, or construction site, or even a dependent agent regularly concluding contracts. The rules are technical and depend on the nature, scope, and permanence of the UK presence.

At BCR we provide clear, practical advice to ensure your business is compliant, efficient, and protected from unexpected liabilities.

Our Approach

Incorrect classification or late registration of a UK PE can lead to significant penalties and reputational risk. It can also affect group tax planning, treaty access, and cross-border transfer pricing positions. By addressing these issues early, BCR helps your business maintain tax efficiency and operational control.

When to assess PE status:

• Expanding an offshore business into the UK market
• Hiring UK-based employees or agents
• Providing services in the UK over an extended period
• Operating through a UK LLP or branch structure
• Buying or leasing UK commercial property

Our Services

We provide support with the following:

• Assessment of whether your UK operations create a permanent establishment
• Guidance on Corporation Tax registration and filing requirements
• Support with setting up UK tax and accounting systems
• Tax compliance services including CT600 filings and iXBRL tagging
• Structuring advice to manage exposure and reduce ongoing tax costs
• Liaison with HMRC and UK professional advisers

Our values in action

Excellence: We navigate complexity with technical precision
Delivery: We ensure that all filing and advisory work is timely and effective
Respect: We understand your commercial drivers and communicate clearly
Elegance: Our support makes international business easier and more transparent

Why BCR Pro

• Experienced in advising on UK PE rules and international structures
• Practical advice based on real-world case experience
• Integrated support across legal, tax, and accounting disciplines
• Focused on delivering sustainable, compliant solutions