Nick Farmer and Steve Hoare recap the rules in determining whether an overseas establishment is a PE, and the implications.
Companies trading in a foreign territory need to consider whether their activities create a taxable presence. Where a treaty exists with the overseas territory the meaning of Permanent Establishment (PE) will be defined and be relevant in determining the taxing threshold. In non-treaty countries the threshold will be based on that country’s domestic law.
Several factors can lead to the creation of a PE so it is important to manage this risk when expanding overseas.
The concept of a...
