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Permanent establishments and subsidiaries

Foreign enterprises at home and abroad can operate in various fields for industrial purposes either by establishing a permanent establishment or a subsidiary. Besides problems with business decisions the question from a tax point of view arises, what is the best organisation or legal form for my company.

Protection against "unwanted" permanent establishments

Permanent establishments can arise unintentionally. This is particularly problematic if a permanent establishment is founded in a county unintentionally, that has a higher tax rates than the country of residence. Even the smallest changes in foreign business can already have uncalculated legal consequences.

Risk of double taxation

Cross-border business activities entail the risk of double taxation. Therefore you have to determine before any activities in foreign countries in which countries you have to pay taxes and which double taxation treaties apply. Furthermore you have to make a correct assessment of the double taxation treaty that has to be applied. We would be pleased to advise you to prevent double taxation.

Our service portfolio:

  • International allocation of income
  • allocation of right of taxation
  • avoidance of double taxation
  • prevention of establishing unintended permanent establishments
  • cross-border co-entrepreneur compensation
  • transfer prices
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