TaxConnections

 
 

Access Leading Tax Experts And Technology
In Our Global Digital Marketplace

Please enter your input in search

Email   Contact Us

Archive for Permanent Establishment

U.S. Tax Treaties: What Is A Permanent Establishment? What Activities Are Generally Not A Permanent Establishment?

U.S. Tax Treaties: What Is A Permanent Establishment? What Activities Are Generally Not A Permanent Establishment?

The Tax Risk Of Permanent Establishment

Recent  developments, such as the Tax Cuts & Jobs Act (TCJA) and the OECD’s Base Erosion and Profits Shifting (BEPS) initiative, have forced multinational businesses to re-evaluate global strategies and the tax impact of doing business abroad.   Navigating the risk of a permanent establishment remains among the most important international tax risks.

While a nonresident alien or foreign corporation engaged in a trade or business in the United States is generally subject to taxation on its net taxable income that is effectively connected with the conduct of the U.S. trade or business, the rules are different (or at least, can be) when a resident of a treaty country conducts the business.  Where a tax treaty is applicable, the concept of a permanent establishment—and whether income is attributable to that permanent establishment—replaces the concept of effectively connected income as the governing standard.

Read more

Permanent Establishment or Not?

Permanent Establishment or Not?

When it comes to tax, trading internationally from a fixed place of business is quite confusing and daunting. If you are trading abroad, the location where the business is wholly or partially conducted can inadvertently create a Permanent Establishment (PE). With different examples, this document will explain how a PE is created and provide a high-level overview of the hidden traps that can trigger a PE.

When it comes to tax, trading internationally from a fixed place of business is quite confusing and daunting. If you are trading abroad, the location where the business is wholly or partially conducted can inadvertently create a Permanent Establishment (PE). With different
examples, this document will explain how a PE is created and provide a high-level overview of the hidden traps that can trigger a PE.

Read more