DOING BUSINESS THROUGH A PERMANENT ESTABLISHMENT (PE)

Abstract

I. OPERATING THROUGH A PERMANENT ESTABLISHMENT 1.03 A. The tax PE threshold 1.03 B. The tests to determine the existence of a PE 1.10 1. The place of business and right of use tests 1.14 2. The location and duration tests 1.19 3. The business connection test 1.23 C. Building sites 1.28 D. Preparatory/auxiliary activities and the anti-fragmentation rule 1.35 E. The Agency-PE: functional analysis 1.48 F. Structures in shipping and air transport 1.72