3.8. Permanent establishments and commissionaire arrangements
| AUTHOR | |
|---|---|
| Juan Carlos Campuzano | |
| lectronic document | |
| Spanish and English | |
| CIAT | June 2024 |
Contents note:
The CIAT Executive Secretariat invites you to download and read chapter “3.8. Permanent establishments and commissionaire arrangements” from the Manual for the Control of International Tax Planning, written by Juan Carlos Campuzano.
This section highlights the importance of the Permanent Establishment concept (PE) as a fundamental element of tax systems when distributing taxing rights related to business income. Likewise, it points out the main challenges that tax administrations face when updating the definition of PE and apply tools to avoid the abuse of the PE construct. Additionally, it offers an annex with a list of definitions of the Permanent Establishment concept of countries in the Latin American region.
Chapter 3.8. is No. 31 published within the framework of the “Manual for the Control of International Tax Planning” and is available in English and Spanish. The complete Manual consists of six sections made up of 42 chapters.