Tax Law

Permanent Establishment (PE)

Definition

A permanent establishment (PE) is a fixed place of business or deemed presence through which an enterprise carries on business in a foreign country, thereby creating a taxable nexus in that country. The PE concept determines whether a country can tax the profits of a non-resident enterprise attributable to its activities there.

Key elements

1A fixed place of business (office, factory, branch, workshop)
2Through which the enterprise carries on business wholly or partly
3An agency PE (dependent agent habitually concluding contracts)
4A service PE (services performed for extended periods — OECD Article 5)
5A construction PE (construction or installation project > 12 months)

How this applies across jurisdictions

India

PE provisions in India's DTAAs and Section 9 of the Income Tax Act 1961 (business connection). India has adopted BEPS Action 7 PE anti-avoidance rules in most of its tax treaties via the MLI. Virtual PEs (significant economic presence) introduced via Equalisation Levy and Section 9(1)(i) amendments.

OECD Model

Article 5 of the OECD Model Tax Convention defines PE. BEPS Action 7 expanded PE definition to counter artificial avoidance (commissionnaire arrangements, specific activity exemptions). The 2017 OECD Model extensively revised Article 5.

UK

TIOPA 2010 and UK DTAAs determine PE. HMRC actively audits PE risks for tech companies and temporary secondments.

Frequently asked questions

How does remote working create PE risks?

If employees work remotely from their home country for a foreign employer's benefit, they may create a fixed place PE or agency PE in their home country. Post-COVID, many countries issued guidance. India has not issued specific guidance, creating uncertainty for cross-border remote work arrangements.

What is an agency PE?

An agency PE arises when a dependent agent (not an independent agent) habitually concludes contracts or plays the principal role in concluding contracts on behalf of a non-resident enterprise. Following BEPS Action 7, the test now covers concluding contracts for the transfer of property or provision of services, not just sales contracts.

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