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.
What EY can do for you
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.
PE Watch Tax Alerts
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
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, China, Hong Kong, Senegal, India, Denmark, Russia, Sweden May OECD, Belize, Cameroon, Denmark, Germany, Switzerland, UAE, Ireland April Thailand, European Union, Germany, India, Denmark, Austria, Singapore March Bahrain, Romania, Nigeria, Denmark, France, Colombia, Netherlands, Denmark February OECD, Lesotho, Thailand, Vietnam, Costa Rica, Denmark, Peru, Russia, Sain, January Seychelles, Finland, France, Denmark, Germany, Ireland, Malaysia
PE Watch alerts
December OECD, Rwanda, Belgium, France, Ireland, Belgium, Portugal November OECD, Indonesia, Russia, Ireland, Mexico, Germany, Denmark, Spain, Germany, Austria, October OECD, Namibia, Andorra, Spain, India, Denmark, Germany, Switzerland, New zealand, Russia, Saudi Arabia September United States, India, Chile, Denmark, Russia, Taiwan, August OECD, Hong Kong, Maldives, Spain, United Kingdom, Denmark, Peru, Ukraine, United Nations July Germany, Austria, Switzerland, Greece,New Zealand, Singapore, Russia, Tanzania, Chile June Australia, Kenya, Sri Lanka, Chile, Denmark, Greece May Canada, Finland, Germany, Switzerland, Belarus, Denmark, India, Saudi Arabia, April Norway, India, Ireland, OECD, Luxembourg March OECD, France, Luxembourg, Russia, Azerbaijan, Austria, Cyprus, Denmark, Italy, Moldova February OECD, Australia, Austria, Germany, Singapore,Germany, Ireland, Spain, January France, India, Finland, Portugal, Ukraine, United States, Germany
PE Watch alerts
December Denmark, Hungary, Iceland, Australia, November Cyprus, Singapore, Denmark, Egypt, Hungary, Portugal, India, Denmark, Peru, October China, Chile, Denmark, Ukraine, Mexico, September Canada, Philippines, Ukraine, Portugal, Latin America, United Kingdom August India, South Korea, Turkey, Ukraine, Austria, Greece, Pakistan, Kenya, July Kazakhstan, Oman, Colombia, Denmark, Spain, Canada, Denmark, Nigeria, United Nations (UN), June Denmark, Italy, Malaysia, Czech Republic, South Korea, Switzerland, Russia May OECD, Hong Kong, India, Indonesia, Singapore, United Kingdom, United States
PE Watch annual publication