permanent establishment
[/ˈpɜːrmənənt ɪˈstæblɪʃmənt/]
nounpl: permanent establishments
estabelecimento permanente
1. A fixed place of business through which a company conducts business activities, which creates tax liability in that jurisdiction under international tax law
The multinational corporation established a permanent establishment in Brazil to manage its operations in South America.
A corporação multinacional estabeleceu um estabelecimento permanente no Brasil para gerenciar suas operações na América do Sul.
2. Under tax treaties, a location where a non-resident business has sufficient presence to be subject to taxation in that country
Opening a permanent establishment requires careful planning due to its tax implications.
Abrir um estabelecimento permanente requer planejamento cuidadoso devido às suas implicações fiscais.
3. A place of business that demonstrates a continuous and settled intention to conduct business operations
The OECD Model Tax Convention defines permanent establishment as a fixed place of business.
A Convenção Modelo da OCDE define estabelecimento permanente como um local fixo de negócios.
In Brazil and Portugal, 'estabelecimento permanente' is a critical concept in international tax planning and compliance. Brazilian tax authorities (Receita Federal) scrutinize foreign companies' activities to determine if they constitute a PE, which would subject them to Brazilian corporate income tax. This term is essential in bilateral tax treaties between Brazil and other countries and is frequently discussed in multinational corporation tax strategies.
Related Idioms & Phrases
establish a permanent establishment
avoid permanent establishment status
trigger permanent establishment
permanent establishment threshold
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