UK subsidiary of Tax Exempt Parent

I have a situation where a UK company is owned 100% by a company in a tax free area.

The companies only function is to act as a marketing presence in the UK and as such its only income is marketing fees from the parent.

Its only expenses are payroll items for its employees and other admin costs ( travel, rent etc)

it has to charge vat on its maangement fees and has taxable profit that it pays CT on.

My question is. Can the company reorganise and act as a branch. If so then presumably it would just be a loss making branch as the Management Fee could be ignored.
Chris Walter