ryan mcrae
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permanent overseas establishment
I work for a broker company in germany on a contract basis where i introduce business. they wish to employ me where I could complete the whole sale and sign the business but are concerned that if they were to do so and I signed business for them whilst being in the UK that it would create a permanent overseas establishment for them. However if I did sign business for them in the UK it would be with clients who are resident in Germany and none of the fees generated from the services (german health and life insurance) would ever come into the UK as they are paid by the German based health and life insurance company to the German based broker business (who wishes to employ me) and by default all the corporate taxes would be paid in Germany. The company does not wish to have to deal with two tax authorities. Given that it is German resident customers taking out German insurance products and none of the fees (all in Euros) that are paid by the German insurers ever comes into the UK does the German broker who wishes to employ me need to file UK corporate taxes? The German tax rate is much higher already and no monies would ever come into the uk except my wages, for which it would set up a payroll but does not want to have to file two sets of corporate taxes in different jurisdiction due to the expense and hassle of having to do so.