More Permanent Establishments: The Dwindling Preparatory and Auxiliary Activities Exception

Volume 6 No 3   |   Read Article

By Neha Rastogi and Beate Erwin

Nothing is certain in this world, except death and taxes – and even taxes are subject to change. The ever-expanding definition of a permanent establishment (“P.E.”) and ever diminishing exceptions to a P.E. under the O.E.C.D.’s B.E.P.S. Project has made one thing clear – the restrictions local jurisdictions put on activities by foreign taxpayers to trigger taxation are tightening. The dwindling preparatory and auxiliary activities exception is a prime example. Neha Rastogi and Beate Erwin explain..  See more →