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For each PFI project a special purpose project company is established by the private sector equity sponsors. It is with this project company that the public sector authority contracts under PFI for the delivery of an asset and services over the project term.For most sectors, the project contract requires the project company to confirm that it is a UK resident company, and to undertake that it will remain so for the duration of the contract.Treasury does not hold information on any PFI contracts that would indicate that project companies have migrated overseas, however Treasury and HMRC cannot verify this as the Treasury does not hold the names of the special purpose project company for each PFI project—this information is held by each procuring authority.UK resident PFI contractors, facilities management services and fund management companies, regardless of their shareholders' registered jurisdiction, are within the charge to UK corporation tax on profits earned within the UK. |