UK Making Foreign PE Exemption Mandatory

UK HMRC has published a policy paper on planned changes in the treatment of foreign permanent establishments (foreign branches). This follows a recent speech by Chancellor of the Exchequer Rachel Reeves, in which she announced that she is bringing forward specific changes to the taxation of foreign branch profits, changing how companies are taxed in relation to their overseas activities. The changes are meant to target certain oil and gas groups that operate overseas through foreign branche…