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Permanent establishment (PE) means having a taxable presence outside your company’s state of residence. Tax authorities are adapting beyond the “bricks and mortar” definition, identifying PEs caused by overseas contractors, short-term business travelers, warehouse space, digital activity and more.
The concept of permanent establishment (PE) has been subject to unprecedented change in recent years. Multinationals should act now to update their PE analysis to align with the current legislative, regulatory, economic, operational and social environment. EY’s global network of subject matter specialists can work with you to update your PE analysis and compliance program and help identify and prioritize the key PE risk areas, the potential impact and other considerations.
Our PE related services include the following:
Global or focused scope PE assessments using bespoke technology (EY’s PE Risk Analyzer), analyzing your activities and specific fact patterns against treaty provisions and the impact of the Multilateral Instrument (MLI).
Specific country advice on the application and interpretation of domestic and treaty provisions.
Transfer pricing assessments to supplement the PE assessment to quantify the future tax costs and help mitigate potential penalties and interest.
Monitoring and periodic updates on PE-related legislative, administrative, judicial and controversy developments.
PE awareness and technical training for tax teams, key stakeholders and other relevant personnel.
Support with the implementation and/or review of PE related governance policies and checklists.
Support with PE and related TP controversy matters.
Permanent establishment in the changing environment
The concept of permanent establishment (PE) has been subject
Monthly publication summarizing the latest developments around permanent establishments (PEs). The publication covers a wide-range of news, from case law, tax rulings, guidance, to legislations and regulations. Also available is our annual PE Watch: in review, which highlights and recapitulates the PE developments in a given year.
PE Watch alerts
Jurisdiction covered
May
India, Denmark, Spain, UAE
April
Switzerland, United Kingdom, Japan, Finland, France, Greece, The Netherlands
March
Qatar, Denmark, The Netherlands, Spain
February
India, United Kingdom
January
Italy, Slovak Republic, UAE, Nigeria
PE Watch alerts
Jurisdiction covered
December
India, Kazakhstan, Denmark, Brazil, United Kingdom, Malta
November
Columbia, Rwanda, India,
October
Mongolia, South Africa, Bulgaria, Türkiye, Finland, Ireland
September
Colombia, Germany, Denmark, Uruguay, Brazil
August
OECD, Finland, Mauritius, United Kingdom, Netherlands
July
OECD, Estonia, Spain, Canada, Maldives, Denmark, Costa Rica, Finland
June
OECD, Estonia, Spain, Canada, Maldives, Denmark, Costa Rica, Finland
The 2021 EY Tax Risk and Controversy Survey finds businesses are bracing for more tax disputes. Learn how to assess and help manage tax risk and disputes.