Permanent establishments - EY

Permanent establishments Recent trends and developments Page 2 Moderator Panel Tom Philibert Albena Todorova Catherine Mbogo Partner EY Senegal Partner EY Mozambique East Region Tax Leader EY Kenya Ide Louw Akinbiyi Abudu Director EY South Africa Partner EY Nigeria Panel Africa Tax Conference 2015 Page 3 Action 7 overview Revised Permanent establishment proposals Profit attribution Updates from across the African continent What should you do next? Africa Tax Conference 2015 Agenda Page 4 Action 7 overview Africa Tax Conference 2015 Page 5 Article 7 Profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a Permanent establishment situated therein. Article 5(1) .. the term Permanent establishment means a fixed place of business through which the business of an enterprise is wholly or partly carried on.

Page 10 Commissionaire is a commercial structure in civil law jurisdictions: Commissionaire acts in “its own name,” but on behalf of the principal What is the OECD’s stated concern? Example in the Revised Discussion Draft illustrates a case involving a business restructuring: Prior to the restructuring, products were sold in State Y by a company resident in State Y and a member of the same

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