Tax Considerations for UK Companies Expanding Overseas: Permanent Establishment, Overseas Subsidiary, and Controlled Foreign Companies
![Image](https://blogger.googleusercontent.com/img/b/R29vZ2xl/AVvXsEgdoQBZw3DCIdHTmjSGxvx2TQvJD2MzwBSK4tqtDTnhP4ps5jQ0wcta24hWcP7p_VVjAGkcTNX0kaRmF-ltoUfnrvXlEebtu9WNNZ3yrIoMgWBQFi22GdYIR1bz5sii5MxMcxvRZCjQSOQTH8V0cHp6UnG0qq1gfCn-JG82gObCxYSRcF2qBTeU8n-pxe9w/w640-h426/Going%20Global.jpg)
When a UK company aims to expand its operations overseas, a variety of options come into play. Photo by Kyle Glenn on Unsplash Permanent Establishment Definition: A Permanent Establishment (PE) arises when a company has a place of management, a branch, an office, a factory/workshop etc, in another country, even if it's not formally registered as a company overseas. It functions as an extension of the parent company and is not a separate legal entity. Considerations: Double Taxation Relief (DTR) : Profit from an overseas PE is subject to UK corporation tax. However, double taxation relief is available if the profit is also subject to taxation overseas. The amount of DTR for this profit is the lower of the tax payable in the UK and in the overseas country. Electing to Tax Overseas : A company can choose to have the PE taxed only overseas. This election is irrevocable and applies to all future PEs of the company. If the election is made, the company may lose relief and capital a