The UK finance bill, which was published on 7 November 2018, includes the legislation required to update UK domestic law to align with the UK’s position on the changes to the Permanent Establishment (“PE”) definition arising from the OECD’s Base Erosion and Profit Shifting (“BEPS”) project and included within the Multi-Lateral Instrument (“MLI”). This effectively expands the definition of PE in the UK which, together with forthcoming changes to many Double Tax Treaties, is likely to result in more PEs arising.
