Where an Irish tax resident trading company expands its operations into overseas markets, the company may be subject to tax in foreign countries if the business has a taxable presence or permanent establishment (PE) there. This may dilute the benefit of Ireland's 12.5% corporate tax rate for the Irish company where the territories into which the company is expanding have higher tax rates than Ireland.
Whether or not a PE exists is a question of fact and each case must be considered on its own facts. The key questions include:
- Ìý
•ÌýÌýÌýÌý Is there a place of business?
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 14:09