A permanent establishment is an office, factory, or branch of a company or other non-resident person in another jurisdiction.
Under double tax treaties, business profits arising from trade in a country are taxable in that country if there is a permanent establishment located within it. The existence of permanent establishments can be subject to dispute as a result.
Permanent establishments may include construction sites or oil platforms in place for over six months. They can also include computer file servers.
Rules regarding permanent establishments can be dependent upon arrangements concluded in double tax treaties.
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