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2023 Navigating Permanent Establishment and U.S. Tax Thresholds

All countries have a threshold of activity beyond which taxation and tax compliance are required. From a domestic law perspective, some countries adhere to treaties, while others, like the U.S., establish their own minimum thresholds to define when and how income must be taxed.

The 2023 Navigating Permanent Establishment and U.S. Tax Thresholds is a high-level guide intended to assist a non-U.S. entity with determining whether its presence in the U.S. is substantial enough for its income to be taxed and to file returns.

This guide supports tax practitioners with resources to navigate U.S. tax thresholds, including:

  • Tax threshold decision tree
  • U.S. domestic law and U.S. Model Treaty
  • PE agency and status commentary on Articles 5(4) and 5(5)

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