The Executive Secretariat of CIAT invites you to download and read section “3.8 Permanent Establishment and the Use of Commissionaire Arrangements” of 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. This involves a use of resources and possibly a modification in the selection of cases to be audited, focusing on operations at risk of abuse of PE status. Additionally, this section offers an annex with a list of definitions of the Permanent Establishment concept of countries in the Latin American region.

This is section number 31 published within the framework of the “Manual on the Control of International Tax Planning”, available in English and Spanish. The complete Manual has six chapters made up of 42 sections. New sections will be published soon.