Permanent establishments (PEs)

Operations across multiple jurisdictions can often create a permanent establishment (PE) in a country other than the country of the entity’s registered office. In these cases, a proper portion of the taxpayer’s income must be attributed to the PE to determine the correct tax liability in the foreign jurisdiction

Our offer


We provide end-to-end support on PE matters, including:

  • assessing whether a PE exists under the given circumstances;
  • correctly determining the tax implications of transactions between the head office and the PE;
  • properly allocating income to the PE in accordance with domestic regulations and international tax standards.
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Andrzej Paczuski

Founder of the Paczuski Taudul law firm. Tax advisor and recognized expert in providing tax advisory services to entities in the financial and real estate sectors.