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Simon Bayliss

Simon Bayliss

Trainee Solicitor at Bristows LLP, a specialist law firm advising clients across technology, life sciences, and innovation.

Aug 5, 2026

3:30
Okay, so if I'm an overseas company that hasn't incorporated a UK subsidiary, what circumstances can mean that my business will be subject to tax in the UK?
3:38
Well, if you're deemed to be centrally managed and controlled in the UK, then the company is tax resident here.
3:45
Or if you're deemed to create a permanent establishment.
3:48
And what creates a permanent establishment? Well, at a high level, you're looking at two common routes.
3:53
First, a fixed place PE.
3:56
Having a place in the UK, an office, a workshop, sometimes even a home office, through which the business is carried on with a degree of permanence.
4:05
Second, a dependent agent PE.
8:03
You're trying to build a narrative that demonstrates if the UK activity were a standalone business, what profit would it earn for doing this work?

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