I have a UK company, which is fully owned and managed by me, who lives outside the UK (i.e. Australia). I understand that a permanent establishment (PE) would be created in Australia. Would the UK company still be taxed in the UK and then double taxation relief claimed in Australia, or would I claim an Australian PE with nil profits in the UK under the double tax treaty? To confirm, it is not a property company, and there are no UK employees in the short term.
Arthur Weller replies:
Article 4 paragraph 4 of
Note - This question first appeared in our February 2018 issue of Business Tax Insider and the answer was not quite clear. So, we are reprinting the question with a clearer answer.
This question was first printed in Business Tax Insider in July 2018.