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3秒自动关闭窗口What is a permanent establishment? | Insights
US multi-national corporations doing business in foreign countries (and foreign based multi-national corporations doing business inside the US or foreign countries other than their own) are typically subject to the domestic tax laws of the countries where they engaged in business activities. However, if the corporation&s home country has entered into a tax treaty with the target country, the treaty will typically provide a higher threshold for taxation than the domestic tax laws applicable in the target country. That higher threshold is commonly referred to as a permanent establishment (PE). Following is a brief discussion of the rules that govern the determination of PE under generic treaty language.Permanent establishmentAs mentioned above, where a corporation&s home country has entered into a tax treaty with a target country, the business operations of the home country corporation are protected from target country taxation as long as those activities do not create a PE in the target country. Typically, a tax treaty defines a PE using the following two general tests:Whether the corporation has a fixed place of business within the target country, as defined under the language of a specific treatyWhether the corporation operates in the target country through a dependent agent that habitually exercises the authority to conclude contracts on behalf of the corporation in the target countryNote that the definition of a PE is typically similar under both the Organization for Economic Cooperation and Development (OECD) model treaty standard language and US model treaty standard language. However, a specific treaty should always be examined for exceptions or differences from standard language.Fixed place of businessUnder the first prong of the PE test outlined above, a corporation must operate in a target country through a fixed place of business to create a PE. A fixed place of business has been defined to include the following types of physical locations:Place of managementBranch or an officeFactoryWorkshopA mine, oil, or gas well, quarry, or any other place where natural resources are extractedHowever, there are exceptions to these general types of locations that do not constitute a PE for treaty purposes. The exceptions are as follows:Use of a facility solely for the purpose of storage, display, or delivery of goods or merchandise owned by the corporationMaintenance of a stock of goods or merchandise belonging to the enterprise solely for the purposes of storage, display, or deliveryMaintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of processing by another enterpriseMaintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise (or collecting information) for the enterpriseMaintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other preparatory or auxiliary activityMaintenance of a fixed place of business solely for any combination of the activities listed aboveBased upon the foregoing, a corporation has many options for doing business in a target country without triggering a PE for treaty purposes. The analysis is highly fact-specific for each case, and the treaty language may vary depending upon the two countries involved in the analysis.Using target country sales agentA PE may also be created in a target country if a corporation operates in that country through a dependent agent. Typically, treaties will provide the following general language addressing the use of agents in a target country:An enterprise of a contracting state shall not be deemed to have a permanent establishment in the other contracting state merely because it carries on business in that other contracting state through a broker, general commission agent, or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that enterprise, he/she will not be considered an agent of an independent status within the meaning of this paragraph if it is shown that the transactions between the agent and the enterprise were not made under arm&s-length conditions.Typically, the analysis to determine whether an agent is working as an independent agent can be determined by examining whether the agent is:Acting in the ordinary course of their businessEconomically independent from the home country corporation that has contracted for their servicesLegally independent from the home country corporation that has contracted for their services.Further, when examining the agency relationship, it is helpful to also identify the category of the agent that has been hired by the home country corporation. For example, agents can be considered any one of the following:An importer or distributing agentA general sales commission agentA consignment agentEach type of agent must always be operating in the ordinary course of their business & and must meet the economic and legal independence tests to protect the home country corporation from being considered as operating a business through a permanent establishment in the target country. In all cases, consideration of the issues discussed above must be made when any client or potential client is expanding their operations into a foreign country.If you would like more information on this topic or have questions please contact your Baker Tilly advisor or send an e-mail to .印度客户需要Tax Residency certificate - 出口交流 -
福步外贸论坛(FOB Business Forum) |中国第一外贸论坛
UID 2084403
阅读权限 40
印度客户需要Tax Residency certificate
我们现在有批货要出到印度，现在货好了然后发邮件通知客户付款。然后客户回邮件说要提供以下2个东西：
A. Tax Residency certificate.
B. A certificate on Letter Head that Machinery Co, Ltd&&do not have any Permanent Establishment in India as&&defined in & Article 5 of Agreement&&for avoidance of Double Taxation of Income& between&&The Government of both the Countries.
请问第一个Tax Residency certificate 这个要怎么弄到呢？？
[ 本帖最后由 香蕉精飞 于
15:42 编辑 ]
(业务QQ： )
代理产地证,商会使馆认证,买 ...
UID 2249623
积分 14707
阅读权限 80
来自 中国商会中心(MOB:)
税务居地证件,它是用来证明某人在某地有纳税记录的文件。可以参考一下
UID 2314290
阅读权限 40
这个真心不懂，路过看一看纯属酱油
源头代理产地证CO/FA/FF/FE
UID 1714734
积分 95549
福步币 550 块
阅读权限 120
来自 源头代理产地证CO/FA/FF/FE
回复 #1 香蕉精飞 的帖子
最好叫客户提供样板过来
当前时区 GMT+8, 现在时间是
Powered by D1scuz! && 2001-permanent establishment什么意思及同义词
沪江词库精选permanent establishment是什么意思、中英文句子翻译、英语短语。
中文释义： 恒久的设施
A military post,especially one that is permanently established.
驻地部队驻地，尤指一种永久性的军事设施
They established their permanent abode here.
他们在此建立了永久居所。
The chancellor should institutionalise the approach and re-establish a permanent reserve requirement regime.
首相应该采取制度化的办法并且重新建立一个常设准备金制度。
超额赔款分保合同
超额赔款率合约再保险，超额损失率分保合同
超额损失率分保
2017permanent establishment是什么意思由沪江网提供。印度客户付款，需要签Permanent Establishment么？ - 外贸单证 -
福步外贸论坛(FOB Business Forum) |中国第一外贸论坛
UID 1529689
阅读权限 25
印度客户付款，需要签Permanent Establishment么？
印度客户要付款，说银行让提供Permanent Establishment文件，带有下面内容：
i.& && &&&The company is tax resident of China and there is no income earned by the Company in I
ii.& && &&&The Company does not have a “permanent establishment” in India (i.e. in the form of a branch office, place of management, dependent agent, etc.) within the meaning of Article 5 of the Agreement.
需要签字给他，大家有遇到过么？ 能不能签啊？ 有什么后果&&请高人指点
(单证不倒翁 Tel:)
UID 301406
积分 43490
阅读权限 120
来自 SHENZHEN,CHINA
回复 #1 fionaxun 的帖子
如果你们公司在印度有办事或分公司，那么肯定签不了，人家银行可能在印度国内调查的
UID 1709395
阅读权限 40
回复 #1 fionaxun 的帖子
个人认为，这就是证明你们公司情况的文件，如果你们公司符合这两点，应该是可以签的
当前时区 GMT+8, 现在时间是
Powered by D1scuz! && 2001-}