Permanent Establishment Reform: What Has Changed, Who Is Affected and Why Does It Matter?

February 11, 2026

Cleary Gottlieb partner Rob Sharpe and associate Iarlaith McCarthy-Hann co-authored the article, “Permanent Establishment Reform: What Has Changed, Who Is Affected and Why Does It Matter?” published in Tax Journal.

Rob and Iarlaith discuss the substantial changes coming to the UK’s Permanent Establishment (PE) rules under Finance Bill 2026—the most significant reform to the PE definition in decades.

Read the article (subscription required).

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Permanent Establishment Reform: What Has Changed, Who Is Affected and Why Does It Matter?