Short answer
Yes. If the company has a fixed place of business in your country, or a person habitually concluding contracts on its behalf there, a permanent establishment can arise and profits attributable to it become taxable in that country.
Non-resident directors
Could my UK company create a permanent establishment in my home country?
Yes, if you have a fixed place of business or a dependent agent concluding contracts there. What creates a PE and the tax that follows.
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.
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Yes. If the company has a fixed place of business in your country, or a person habitually concluding contracts on its behalf there, a permanent establishment can arise and profits attributable to it become taxable in that country.
01
What creates a PE
02
Consequences and how to manage it
What creates a PE
A fixed place of business such as an office, workshop or, in many countries, a home office used regularly for the business. A dependent agent PE arises where someone habitually plays the principal role in concluding contracts for the company, even without a formal office.
Preparatory and auxiliary activities, such as storage or information gathering, are usually excluded, but the exclusions are narrower than most founders assume, and many countries apply anti-fragmentation rules.
Consequences and how to manage it
A PE means registering and filing locally, attributing an arm's length profit to the PE, and paying local corporate tax on it, with UK double tax relief for the overseas tax. Administratively it is the same work as running a local company, without the clarity.
Where meaningful activity happens in your country, a local subsidiary with a transfer pricing policy is often cleaner than an accidental PE discovered later. Take local advice; UK advice alone cannot answer a foreign PE question.
Before you act
Rates, thresholds and deadlines quoted 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.
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
Could my UK company create a permanent establishment in my home country?: questions directors ask
Does working from my home abroad create a PE?
It can, particularly where the company has no other premises and the work is habitual and core to the business.
Is there a time threshold?
For construction and installation projects, treaties often use six or twelve months. For other activities, permanence is judged on facts.
Does a PE mean double tax?
Not usually. Relief is given by credit or exemption, but compliance costs in two countries are real.
What records are needed for could my uk company create a permanent establishment in my home country?
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 could my uk company create a permanent establishment in my home country 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 could my uk company create a permanent establishment in my home country 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 could my uk company create a permanent establishment in my home country 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 could my uk company create a permanent establishment in my home country?
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 could my uk company create a permanent establishment in my home country?
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.
Is this could my uk company create a permanent establishment in my home country guidance personal tax advice?
No. This page explains general UK rules and common accounting treatment. Your facts, contracts and wider tax position must be reviewed before you rely on a conclusion.
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Check the current rules
Use official information as your reference point.
Deadlines, thresholds and filing rules change. GOV.UK and Companies House publish the current statutory position; advice should then be applied to your company’s circumstances.