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The dangers of creating an accidental PE and how to avoid it

November 28, 2014

Sophie Ashley



As companies’ employees become more globally mobile, there is an increasing risk that a permanent establishment (PE) may occur unintentionally, leaving taxpayers at risk of taxable income liabilities.

It is important for companies to understand where unintentional PEs can occur and how to avoid them because, once a PE has been created, there is no way back for the company, which will have to pay the jurisdiction in question for any taxable income, until the situation has been reversed.

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