Part 24Corporation Tax Acts definitions etc
Chapter 2Permanent establishments
Circumstances where there is no permanent establishment
1142Agent of independent status
(1)
A company is not regarded as having a permanent establishment in a territory by reason of the fact that it carries on business there through an agent of independent status acting in the ordinary course of the agent's business.
F1(1A)
A person is not to be regarded for the purposes of subsection (1) as an agent of independent status in relation to a company where the person—
(a)
is closely related to the company, and
(b)
acts exclusively or almost exclusively on behalf of—
(i)
the company, or
(ii)
the company and other companies to which the person is closely related.
(1B)
In subsection (1A), “closely related” has the meaning that it has in section 1143 (see subsection (2CA) of that section).
(2)
Sections 1145 to F21150 F3modify the application of this section in relation to transactions carried out on behalf of a non-UK resident company by a person in the United Kingdom acting as—
(a)
a broker (section 1145), F4or
(b)
an investment manager (sections 1146 to 1150), F5...
F5(c)
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .