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Assume, in example 2-2, that several sales are closed in the United Kingdom and that the Sessions Group London office hires a permanent full-time employee to fulfill post-sale service requirements. Arguably, the presence of a full-time employee creates a taxable presence under United Kingdom tax law and, if so, the Sessions’ London office is a QBU.

A trade or business is a unified group of activities that constitutes an independent economic enterprise carried on for profit. A trade or business must ordinarily include every operation, which forms a part of, or a step in, a process by which an enterprise may earn income or profit. A vertical, functional or geographic division of the same trade or business is itself a trade or business if it is capable of producing income independently.