Market leading insight for tax experts
View online issue

BEPS: Preventing the artificial avoidance of the permanent establishment status

Speed read

The amendments to the permanent establishment threshold as part of the BEPS project have potentially far reaching consequences for cross-border trading activities. The first changes amend the deemed ‘agency permanent establishment’ concept. The second set of changes focuses on fixed place of business permanent establishments. An increased compliance burden is expected, even in cases where no additional tax is levied. Cases will turn on their facts, but a number of concepts are open to interpretation and will cause uncertainty for international businesses. Further work on the attribution of profits to permanent establishments is expected (by 31 December 2016) and will be essential in determining the consequences of a newly created taxable presence.

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top