Permanent establishment (PE) is the threshold at which a foreign company becomes taxable where it operates: a fixed place of business, a dependent agent habitually concluding contracts, or management actually exercised locally. For one-person companies, the owner’s laptop is the PE risk — the company is wherever they work. It’s the same substance logic that decides remote-work sourcing questions under regimes like Law 7582, and it’s why “my company is offshore” rarely ends the analysis.
Permanent establishment
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