The Government Amendments to Domestic Permanent Establishment Rules

The U.K. government has released draft amendments to update its permanent establishment rules and the Investment Manager Exemption, aiming to align with OECD standards and address the evolving needs of the asset management sector. Partner James Anderson and associate Lorenza De Domenico discuss the implications of these changes, including the expanded scope of “dependent agent” permanent establishment, the narrowing of the agent of independent status exemption and the repeal of the “20% rule,” highlighting both the opportunities and challenges they present for nonresident funds, family offices and U.K. investment managers.