INTM264450 - Non-residents trading in the UK: permanent establishment: domestic and treaty law: fixed place of business: places especially included within the definition of permanent establishment
Fixed place of business permanent establishment - places especially included within the definition of permanent establishment
The model treaty at Article 5(2) and domestic law at CTA2010/S1141(2) give some specific examples of what is 鈥渆specially included鈥� in the term permanent establishment these are listed in INTM264300 The two lists are virtually identical.
Neither is an exhaustive list of the places that could be a permanent establishment. Furthermore, it is clear from the Commentary in order for any of these places to constitute a permanent establishment they would also need to have the general attributes of a fixed place of business, i.e. the geographic, period of duration and personnel conditions must be met.