Permanent Estabhlishments

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Permanent Establishments

Our “International Tax and Permanent Establishment – PE Compliance” team assists multinational corporations as well as small and medium-sized enterprises with the planning, implementation, and ongoing compliance of permanent establishments (PEs) worldwide. Our services cover the entire value chain—from assisting with registration preparations, to ensuring compliance with periodic accounting and tax reporting obligations, to final deregistration.

A permanent establishment creates a local tax connection with far-reaching legal and tax consequences. We ensure that your permanent establishments are correctly structured, legally compliant, and efficiently integrated into your group processes and systems at every stage of their lifecycle.

Services

International Tax

Our TaXpertise Centers combine tax, business, and cultural expertise on selected regions of the world located in Germany. Native-speaking experts with many years of practical experience offer fast, coordinated advice from a single source—for efficient, clear, and tailored solutions for cross-border business transactions.

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Our Service Portfolio for Permanent Establishments

Each of these service modules can be combined, customized, or commissioned as a single task or process step according to your needs.

Strategic PE Valuation & Structuring

Analysis of business activities to identify PE risks and opportunities
Design of tax- and risk-oriented PE structures (project PEs, branches, representative offices)
Alignment with international tax regulations
(e.g., OECD PE standards, transfer pricing)
Design of onshore/offshore profit allocation schemes and documentation

PE Implementation & Registration

Coordination and support for global PE registrations
Establishment of legally compliant PE processes and responsibilities (PE governance)
Integration of PEs into your ERP and reporting environment (e.g., project structures, cost centers, profit centers, PSP elements)
Preparation and review of PE-related contractual frameworks

Ongoing PE Accounting, Reporting, and Tax Compliance

Development and implementation of PE accounting solutions (e.g., using system-supported Windows-based reporting, PE accounting data extracted from the source system, or through separate company code-based or derived solutions)
Preparation or coordination of local financial statements for permanent establishments (PEs) based on international or local accounting standards
Ongoing tax compliance: Preparation and/or review of corporate income tax, withholding tax, sales tax, and payroll tax returns
Monitoring of deadlines, formal requirements, and documentation obligations
Assistance with tax audits and communication with local tax authorities

Governance, Risk Management & Internal Control

Establishment of group-wide PE governance and approval processes
Design of internal control systems to prevent unintended PEs
Regular reviews of PE structures, profitability, and tax risks
Sharing of best practices and training for finance, tax, and project teams

PE Lifecycle Management & Deregistration

Ongoing monitoring of PE status and termination criteria
Planning and implementation of PE closures and liquidations
Coordination of local deregistrations and final tax returns
Cleaning up PE data in internal systems and documenting the entire lifecycle

Marco Küpper

Partner Tax

Düsseldorf

+49 9131 97002-22

marco.kuepper@wts.de

Martin Weingarten

Director

Nürnberg

martin.weingarten@wts.de

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What We Offer

Who we work for…

Simple answer: For you! That means…

Large corporate groups with complex project structures and numerous project entities (PEs) in different jurisdictions
Mid-sized companies in growth or internationalization phases that require robust and scalable PE processes
Project-driven companies (e.g., energy, infrastructure, construction, engineering, services) with recurring cross-border projects

In all circumstances, we work for you, we work with you, and we act as a service provider and partner to design structures and processes tailored to your requirements.

Our Added Value

Holistic life-cycle approach: from the initial PE risk analysis through setup and operational compliance to deregistration
Combination of international tax and implementation expertise (processes, systems, ERP integration)
Scalable solutions for large global structures and focused mid-market operations
Risk minimization through clear governance, robust compliance, and proactive management of PE-related tax risks

We help you ensure that your permanent establishments worldwide remain compliant, are managed efficiently, and are optimally aligned with your business model—so that international growth does not become a tax risk, but rather remains a strategic advantage.

Workmanagement plattform

ITP ProjectManager

The ITP ProjectManager provides a comprehensive digital representation of international projects across all process steps—from proposal preparation and contract negotiation to ongoing project execution. Tax implications become apparent early on and can be directly incorporated into project cost estimates and efforts to ensure compliance both domestically and abroad. Through clear workflows, precise task assignment, and transparent deadline management, the platform supports collaboration across national and departmental boundaries.

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Further topics you could be interested in

International Tax Desks

Permanent Establishments

Global Trade & Green Taxes

Corporate Tax

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Do you have any questions about our services or WTS? Please let us know. Please fill in our short contact form. We will get in touch with you as soon as possible.

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