The Permanent Establishment Concept in the 2016 U.S. Model Income Tax Convention

Summary

This practice note provides an overview and evaluation of the concept of a permanent establishment in the 2016 U.S. Model Income Tax Convention (2016 Convention). An understanding of the concept of a permanent establishment is important in advising your client on the actual and potential tax implications relating to that concept and arising from the client's business activities in a country that has entered into income tax treaty with the United States.