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Episode 1 - PE or not PE: That is the question

FS Transfer Pricing Decoded - A global tax podcast series

The first episode of the series discusses a topic which many organisations are increasingly having to assess and manage from a tax perspective – staff working from outside of their country of employment. So when can such movement of staff create a permanent establishment (PE) for corporate tax purposes and what are some of the key personal tax consequences to think about? In this episode listen to Stephen, Louise, Giles and Murray; where they discuss these points through case studies.

Case study questions:

Example 1: A middle office employee, employed by a French entity, is forced to work remotely in the UK.

  • What are the basic PE principles and personal tax consequences to consider?
  • What changes if they now choose to work in the UK?
    Would it matter if their employer gave them a home work contract and for a longer period?
  • What if colleagues from other departments were working from home in the same country?

Example 2: A sales person works remotely in their home before relocating to the country of their new employer.

  • What are the PE considerations in this example?
  • What happens if they adopt a split working model working in both countries?

Profit Attribution – if transfer pricing principles are followed, can the PE considerations be ignored?


  • Stephen Weston | Partner – Deloitte UK
  • Louise Wilson | Partner – Deloitte UK
  • Giles Hillman | Partner – Deloitte UK
  • Murray McLaren | Partner – Deloitte UK

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