The US Court of Federal Claims has decided a third case (National Westminster Bank PLC v. United States, Docket No. 95-758T (16 December 2005)) involving NatWest bank, this time holding inter alia that the multiple US branch offices of the bank could be combined to form a single permanent establishment (PE) under the 1975 United States-United Kingdom income tax treaty.
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OrbitaxUS Court
decides third NatWest case – multiple US branches combined to form single PE under 1975 US-UK treaty