Permanent establishment

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.

Related topics Tax Tax transparency

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.

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