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Area 03 / 10
We review offices, personnel, projects, agents and contracting practices to assess potential taxable presence under relevant domestic rules and treaties. Where exposure is identified, we assess the implications for registration, profit attribution and the way activities are organised.
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Every assignment starts with your records, transactions and the question that needs answering.
Back to International Tax
We review offices, personnel, projects, agents and contracting practices to assess potential taxable presence under relevant domestic rules and treaties. Where exposure is identified, we assess the implications for registration, profit attribution and the way activities are organised.
We collect the operational facts - travel patterns, home-office arrangements, project durations, who negotiates and signs, what stock or equipment sits where - and test them against fixed-place, agency and project thresholds in the relevant rules and treaty. Where a taxable presence likely exists, we quantify the attributable profit and the registration consequences; where it can be legitimately managed, we set out the operational changes required.
A PE risk assessment by country and activity, with attribution analysis and recommended operating protocols.
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Tell us about your permanent establishment analysis requirements. We will outline the scope and next steps.