It seems that the Government are looking to tackle the issue of profit flow out of the UK through licensing fees and intellectual property arrangements which depress the tax paid by technology companies - the so called "Google Tax" - by reviewing permanent establishment rules. We assume that the royalty arrangements between a UK company and a non-resident company may be brought into the UK tax net possibly by saying that the UK company is acting as agent on behalf of the non-resident parent and therefore the non-resident is permanently established in the UK.