The exclusion for warehouses, such as Amazon\’s eight distribution centres, is contained in the double taxation treaty the UK negotiated with Luxembourg in 1966. Amazon.co.uk is registered to a Luxembourg company, Amazon Europe Holding Technologies SCS, and the site runs off the group\’s servers in Ireland.
And that is indeed the standard OECD double taxation treaty.
The Guardian\’s investigation into the rules on permanent establishment involved looking at HMRC manuals, international double taxation treaties dating back to the 1960s, and guidelines for tax treatments of multinational businesses set out by the Organisation for Economic Co-operation and Development.
Of course, they could have just read this blog…..