Corporate PE risk scorer — free calculator
Scores the factors that create a permanent establishment, so the exposure can be discussed before it is assessed.
- 15+Years of cross-border experience
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Scores the factors that create a permanent establishment, so the exposure can be discussed before it is assessed.
Enter your figures
An estimate for planning only. Rates and thresholds used here are the assumptions stated on this page; we confirm every figure against the issuing authority for your own tax year before anything is filed.
How the estimate is built
A permanent establishment can be created by a place or by a person. Premises and regular employee presence are the classic fixed-place factors; someone who habitually concludes contracts, or plays the principal role leading to them, creates a dependent-agent presence with no premises involved. Construction and service activities have their own duration thresholds in many treaties, which is why the time question is scored separately.
How to get this moving
A calculator narrows the range; it does not settle a filing. We would rather scope it properly than quote it quickly.
Read and approved for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.
Corporate tax calculator, in practice
If you came here for corporate tax calculator, this is where it is dealt with. The subject is corporate PE risk scorer, and the page covers who it reaches, what then has to be filed, and what we charge to do the work.
Why choose Legal Quotient for corporate PE risk scorer calculator
We say early if it is not our work
If a file needs something this practice does not do, you hear that at the start rather than after a bill.
Cross-border is the whole practice
International and cross-border tax is all we do — not a sideline next to domestic work. The edge cases on this page are our ordinary Tuesday.
One team, not two firms billing separately
You are not the go-between for two sets of advisers with two sets of assumptions. One engagement covers each country the file touches.
Both sides prepared together
Two returns built against each other by one team, so relief is claimed exactly once and nothing falls between the two systems.
Cross-border tax case studies
Scoring an arrangement before the first foreign hire
A software company was about to put its first employee in another country and wanted to know what that created before the offer went out. We ran the factors with them: no premises, one employee working from home, and an intention that the role would negotiate but not sign. The negotiating point was the live one, so we looked at how deals would actually be approved and by whom. The engagement produced a written analysis of the proposed role, a set of limits on what the employee could commit the company to, and a note of what would need re-scoring if those limits moved.
A consultancy whose contracts were signed at home but closed abroad
Every engagement letter was executed at head office, which the directors treated as settling the question. Their local partner, though, agreed scope, price and timing with clients, and head office had never altered a deal that came back. We documented the approval trail, interviewed the people involved, and set out how the arrangement looked against the dependent-agent test rather than the signature. The engagement produced a written position, a change to the approval process so that review was substantive rather than formal, and a record of when the new process took effect.
A construction project that ran longer than the tender assumed
A contractor won work abroad on a programme it expected to complete quickly, and delays extended it well past the original schedule. Because construction activity carries its own duration threshold in the applicable treaty, the exposure turned on when the site clock started and whether related contracts counted as one project. We assembled the site records, mobilisation dates and subcontract chain, and read them against the treaty in force. The engagement produced a dated chronology of the site, a position on when the threshold was crossed, and a registration and filing plan from that date.
Equipment left on a customer site between jobs
A manufacturer stored testing equipment at a client's plant abroad because moving it back each time was impractical. Nobody had asked whether the space was at the company's disposal. We established who controlled access, whether the company could use the area for its own purposes, and what its staff did while on site. The facts sat close to the line, which the directors had not appreciated. The engagement produced a documented analysis of the arrangement, a revised site agreement that made control of the space explicit, and a scoring exercise repeated after the change.
Answering a foreign questionnaire about local staff activity
A tax authority wrote to a distributor asking what its people in that country actually did. The company's first draft reply described job titles. We rewrote the approach: gathering the evidence first, then answering only what was asked, with the contracting facts set out in the sequence the treaty test follows. Where the evidence was incomplete we obtained it before replying rather than generalising. The engagement produced a documented factual response, supporting records indexed to each answer, and a written internal position the company could rely on if the enquiry went further.
Rebuilding an agency relationship into an independent distributor
A group sold through an agent who took orders, set discounts within a range and invoiced in the group's name, which put the contracts factor at its heaviest weighting. The directors wanted the exposure removed rather than argued. We mapped what the agent did, identified which activities created the risk, and worked through what a genuine buy-and-resell arrangement would require in terms of title, stock, pricing risk and customer contracts. The engagement produced a restructured distribution agreement, a note of the date the old arrangement ended, and a rescoring of the position under the new terms.
One Salesperson Abroad, and a Corporate Filing Obligation
A single employee with authority to conclude contracts can create a taxable presence for the whole company. The review tests what the person actually does against the treaty article, and where a presence exists, works out what profit is attributable to it.
Read how this one runsCanadian Pension Paid Abroad and Taxed at the Flat Rate
Pension and annuity payments to a non-resident carry a flat withholding that often exceeds what a return would produce. The alternative filing is elective, and whether it helps depends on the total income for the year rather than on the payment alone.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
International Tax Planning & Advisory
Strategy and compliance for income, assets and families spread across borders.
U.S. & Cross-Border Tax Returns
Expat & Emigration Tax
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Transfer Pricing & BEPS
Tax Treaties & Withholding
Cross-Border Estates & Trusts
Global Investments & Reporting
Cross-Border Corporate Tax
India Tax for NRIs & Returning Residents
Canadian Tax with a Foreign Element
UAE Tax for Expats & Their Home Country
Industries & Client Types We Serve Worldwide
Global E-commerce & Marketplaces
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
Technology & SaaS
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
Professional Services Firms
Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.
A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
Cross-Border Real Estate
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Importers, Exporters & Manufacturers
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Athletes, Artists & Entertainers
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
Remote Workers & Digital Nomads
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
Investment Funds & Holding Companies
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
