The question arises from non-resident companies in carrying on business activities in the source country, whether to carry on business through a Permanent Establishment (PE)? The answer to this question might be “yes” and “no”. If so, for those who want to carry on their business activities through a fixed place of business, dependent or independent agents, and hope can certainly carry on their business activities in the source country. Unless, if non-resident intended to avoid administrative tax burden in source country or in other words, not subject to domestic taxation therein.
However, to determine the existence of a PE, it needs to consider the relevant factors associated with the time threshold or the activity undertaken in the source country. Not to mention the existence of the declaration of the G20 with the OECD, which include the issue of PE in 15 Plan of Action on the issue of the Base Erosion and Profit Shifting (BEPS Action Plan). BEPS Action Plan 1, the OECD and the G20 will focus on addressing issues in PE that was developing in the information technology industry and digital communications. Then BEPS Action Plan 7, the OECD and the G20 will lower the threshold of PE to provide more taxing rights to the source country.
In this valuable seminar, you will capture clearly concept of PE in performing cross border transactions between the companies in treaty partner.
With material that we have to offer the following: