Permanent establishment

In Swiss and treaty tax law, a permanent establishment creates a taxable presence separate from the enterprise’s residence or seat. Typical examples include a branch, office, workshop, factory, construction site of sufficient duration, or a dependent agent with authority to conclude contracts. Profits attributable to the permanent establishment may be taxed where it is located, requiring allocation of income, expenses, assets and sometimes capital. The precise definition varies between domestic law and applicable double tax treaties, so treaty wording and facts are decisive.