International Tax In Essence (Video Episode 5): PE Overview

December 14 2022

This video provides an overview of fixed place permanent establishment (PE) in the contemporary tax treaties. It also covers aspects such as:

  1. Macro elements of a fixed place PE;
  2. Features of a place of business; and
  3. Requirements for a place of business to be considered 'fixed'.

 For patrons:

Case Note: Remotely operated underground pipeline regarded as fixed place permanent establishment.

Case Note: Facilities in a contract manufacturer's premises amounted to a foreign enterprise's place of business.

For subscribers and Patrons:

Could a home office amount to a permanent establishment?

Could a client's office premises or a residential apartment give rise to a consultant's PE?

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