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Contains Parliamentary information licensed under the Open Parliament Licence v3.0. Contains public sector information licensed under the Open Government Licence v3.0. © Parliamentary copyright. © Crown copyright.

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POLICYWithdrawnPolicy paper · gov.uk

Reform of the foreign permanent establishment exemption

This measure reforms the taxation of foreign permanent establishments, making the elective exemption regime that applies to their profits and losses mandatory for Corporation Tax.

Last fetched 13 Jul 2026 · gov.uk
Documents
Draft legislation (accessible version)Explanatory noteapplication/vnd.oasis.opendocument.textCorporation Tax — reform of the foreign permanent establishment exemption Draft legislationapplication/pdf
At a glance
TypePolicy paper
First published13 Jul 2026
Last updated13 Jul 2026
Organisations
HM Revenue & Customs
Topics
Corporation Tax
Source
Open on gov.uk
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