Are you seeking to better understand Permanent Establishments (PEs) and when a taxpayer should consider these provisions in further detail?

In this second episode of Tax Chats (International Tax 101), Danielle provides you with a quick and concise overview on some of the common PE risks and complexities to keep an eye out for.  

Tax Chats (International Tax 101) with Danielle Sherwin is designed to provide you with quick and practical insights into relevant international tax matters to assist you (or your clients) in identifying and understanding potential international tax and transfer pricing risks before any ATO review activity. 

Key takeaways

1. Identifying a PE is not easy and requires consideration of the relevant Double Tax Agreement to the taxpayer’s specific facts and circumstances. 

2. Key risk factor would include employees performing work in another country. 

3. Profit attributable to the PE is determined in line with transfer pricing principles. 

Danielle Sherwin

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International Tax 101: Permanent establishments | Episode 2

Danielle is a Principal in the Tax Services division in the Sydney office. 

Danielle specialises in international tax, with a focus on transfer pricing and international tax. She assists her clients with their international tax planning and transfer pricing needs, ranging from Significant Global Entities (SGE) assessment, Country-by-Country (CBC) reporting, transfer pricing planning and advisory to transfer pricing compliance and documentation. 

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