Branch’s registration is not decisive for its liability to taxation
In principle, a branch’s registration is not decisive for its liability to taxation,
as formal registration is not part of the tax treaty definition of permanent
establishment.
However, in practice, a registered branch will almost always
rank as a permanent establishment, simply because of the registration
condition that it be running an independently functioning business, whereas
an unregistered liaison office or other entity may or may not be a tax treaty
permanent establishment, depending on the nature and scope of the activities
carried out and the responsibilities borne.
EU Forecast
euf:ba18e:73/nws-01