United Kingdom Tax Agency Issues Policy Paper on Corporation Tax Foreign Permanent Establishment Regime Changes

The United Kingdom HM Revenue and Customs May 21 issued a policy paper on the government’s proposed changes to the corporation tax regime for U.K.-resident companies conducting part of their business through foreign PEs. The policy paper describes measures to: 1) require the exemption from U.K. tax of profits and losses attributable to foreign PEs, for accounting periods beginning on or after Jan. 1, 2027, or from Sept. 1, 2026, for companies engaged in oil and gas exploration or extraction; 2) specify that losses and other attributes arising in years before the exemption takes effect can’t relieve the U.K. profits ...