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Permanent Establishment

A fixed place of business or sufficiently significant business presence in a country, which can make a foreign business subject to that country's taxation.

A permanent establishment is a fixed place of business, or a sufficiently significant ongoing business presence, that a foreign business maintains in a country — generally the threshold that makes that business subject to taxation in that country on the income attributable to that presence.

This concept is most relevant to crypto businesses (exchanges, mining operations, protocol development teams) operating across borders, rather than to individual investors, since an individual's tax obligations are generally governed by tax residency (see Kaavon's "Tax Residency" glossary definition) instead.

Examples

  • A crypto mining operation with physical hardware running continuously in a specific country can constitute a permanent establishment there, even without a traditional office.
  • Permanent establishment is primarily a business-taxation concept; individual investors are generally governed by tax residency rules instead.

Learn more

Concept

Tax Residency

Read the Tax Residency glossary definition

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