Permanent establishment (PE)

Roles that need it

• Tax Associate
• Transfer Pricing Analyst
• Legal Counsel

Skills it belongs to

• Corporate taxation
• Intercompany transfer pricing

Related concepts

• Transfer pricingTransfer pricing sets the prices of transactions between entities of the same group, such as services, loans, guarantees and intangibles. Tax rules require the arm's length principle: prices independent parties would agree. OECD guidelines set methods and documentation (master file and local file).
• Double tax treaty (DTT)A double tax treaty is an agreement between two countries that allocates taxing rights on income such as business profits, dividends and interest, so the same income is not taxed twice. Most follow the OECD Model. In the EU, disputes under treaties can go to a binding resolution procedure.
• Pillar Two (global minimum tax)Pillar Two is the OECD and G20 global minimum tax of 15 percent on the profits of groups with consolidated revenue of at least EUR 750 million, measured jurisdiction by jurisdiction. The EU adopted it in Directive (EU) 2022/2523 with top-up taxes from 2024.

Sources

• Council Directive (EU) 2022/2523 on a global minimum level of taxation, EUR-Lex (external site) accessed 31 Oct 2026
• OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, OECD (external site) accessed 31 Oct 2026

Updated 31 Oct 2026.