Tax residence and permanent establishment

My UK company has all its operations overseas — where is the profit taxed?

A UK-incorporated company is taxed here on worldwide profit regardless of where operations sit, with treaty relief reducing double taxation abroad.

Short answer

The UK, first, because incorporation alone makes the company UK tax resident and chargeable on worldwide profit. If operations abroad also create local residence or a permanent establishment there, that country can tax its share too, with double tax relief reducing, but not always eliminating, the overlap.

Written and reviewed by Waqas Sagar Member of ICAEW, Fellow of ACCA, Fellow of AAT, a double graduate and entrepreneur at heart, helping startups grow and serving thousands of businesses nationwide with an excellent team. Published by LimitedCompany.Accountants, 12 London Road, Morden, London SM4 5BQ. Reviewed 12 September 2026 against 2026/27 UK rates and current Companies House and HMRC guidance.

What this means for your company

The UK, first, because incorporation alone makes the company UK tax resident and chargeable on worldwide profit. If operations abroad also create local residence or a permanent establishment there, that country can tax its share too, with double tax relief reducing, but not always eliminating, the overlap.

01

Two separate questions

02

Getting relief

Two separate questions

First, is the UK company UK resident: almost always yes, by incorporation. Second, does the overseas activity also create a taxing right for another country, either through local residence under central management and control or through a permanent establishment there.

Both questions can have a 'yes' answer simultaneously. That is not unusual or necessarily a problem, but it does mean two sets of compliance obligations and the need for a plan to relieve any double taxation.

Getting relief

Where a double tax treaty applies, credit or exemption relief usually stops the same profit being taxed twice in full, though timing mismatches, different profit calculations and non-treaty countries can still leave some residual double taxation.

Filing correctly in both countries, keeping consistent transfer pricing and profit attribution workings, and taking local advice on the foreign side are the practical steps, since the UK return alone cannot manage the foreign exposure.

What this costs with us

Our fixed monthly packages for a UK limited company start at £89 plus VAT and run to £169 and £289 plus VAT as bookkeeping, VAT, payroll and reporting are added. One-off filings are sold at fixed prices, and the Companies House fees we pay for you are charged at cost with no VAT added. Overseas owners are quoted on exactly the same published prices as UK-resident clients.

Before you act

Rates, thresholds and deadlines here reflect the 2026/27 UK position and current Companies House and HMRC guidance. Check GOV.UK, or ask us, before relying on them for your own company.

Primary references

Official sources and further reading

Related answers

More on tax residence and permanent establishment

Every answer in this cluster is written for UK limited company directors and reviewed against current HMRC and Companies House guidance.

Local help

Talk to a limited company accountant near you

We work with company directors across London and Surrey from our office at 12 London Road, Morden, London SM4 5BQ. Pick your area, or send the form below and we will call you back.

Frequently asked

My UK company has all its operations overseas — where is the profit taxed?: questions directors ask

Is this arrangement illegal?

No, it is a common structure, but it needs correct compliance in both countries and honest profit attribution.

Should I dissolve the UK company instead?

Not automatically; it depends on your commercial reasons for using it and the tax outcome of alternatives.

Does HMRC share this information with other countries?

Often yes, under international exchange of information agreements, so undeclared foreign presence is a real risk.

What records are needed for my uk company has all its operations overseas — where is the profit taxed?

Keep bank statements, sales and platform reports, purchase invoices, payroll records, VAT workings, finance agreements and Companies House correspondence. We confirm the exact list at onboarding and identify gaps before a filing deadline becomes urgent.

How much does help with my uk company has all its operations overseas — where is the profit taxed cost?

The fee depends on transaction volume, record quality, VAT and payroll requirements, historic catch-up and the level of reporting needed. We agree a fixed scope and price before technical work starts, with published packages available on our fees page.

Can you take over my uk company has all its operations overseas — where is the profit taxed from another accountant?

Yes. We request professional clearance, collect the prior records and authorities, check the next Companies House and HMRC deadlines, and give you one clear handover list. The process is normally completed remotely.

Can my uk company has all its operations overseas — where is the profit taxed be handled online?

Yes. We work through secure cloud records, scheduled reviews and digital approvals, while keeping a named team available by phone, video call and email. Clients can also visit our Morden office by appointment.

Which accounting software works best for my uk company has all its operations overseas — where is the profit taxed?

We regularly work with Xero, QuickBooks, FreeAgent, Sage and connected sales or expense apps. The right setup depends on transaction volume, integrations and the reports you need, not simply the software brand.

What tax deadlines matter for my uk company has all its operations overseas — where is the profit taxed?

The relevant calendar may include annual accounts, Corporation Tax payment and return dates, confirmation statements, VAT returns, payroll submissions and Self Assessment. We map the dates from your company year end and registrations.

Can I get free basic tax advice about my uk company has all its operations overseas — where is the profit taxed?

Yes. You can ask a straightforward initial question without charge. Calculations, filings, written advice, planning and HMRC correspondence are scoped and quoted before work begins.

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