In general, branches and resident companies are taxed alike (i.e. taxation of corporate profits is postponed until profit distribution). As with companies, a PE's taxable base is a sum of taxable items consisting of profit distributions and deemed distributions. However, the PE's taxable base consists not only of taxable items incurred directly through the PE, but also of any taxable items the non-resident allocates to the PE.
As a subscriber you will be able to read full content, access our archive of articles, view useful resources, and put questions to PwC consultants.
Free trial Sign in
