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Word of caution, the activities of the employee can trigger a PE for your company and expose you to corp income tax, and depending on possible "technical servic
by not_a_moth 6y ago
Word of caution, the activities of the employee can trigger a PE for your company and expose you to corp income tax, and depending on possible "technical service" clauses in domestic law or tax treaty between the two countries, you can be liable to more taxation in the host country even without a PE.
Plenty of tax treaty case law showing audits do happen to all of MNCs, small companies, and individuals in these matters, with financial and even criminal penalties for your directors in some jurisdictions.
BEPS is also now cracking down on PE avoidance and types of arrangements/facilitators out there.
Sometimes better, and easier, to just declare and manage a PE. Employment services firms don't offer actual legal protection here since doesn't matter if direct or indirect employed.