Case study 1
A visiting sales engineer who settled the commercial terms
A foreign enterprise sent an engineer to meet customers in a country where it held no premises. Head office signed every contract, and on that basis the company had concluded it had no taxable presence. Our work was in the correspondence: the engineer had agreed specification, delivery and price, leaving head office to countersign. We set out what the person limb of the test actually asks, documented the negotiating record customer by customer, and identified where authority in practice had sat. The engagement produced a written position, a revised description of the role, and instructions on the approvals that would need to change to support it.
Case study 2
An installation project that ran across consecutive seasons
A contractor worked at a single site over successive periods, leaving between them and returning with the same crew to continue the same work. The company treated each visit as a separate short engagement. We examined whether the activity was one project with interruptions or genuinely distinct undertakings, working from the contract, the scope documents and the site records. Continuity, not the number of trips, decided it. The engagement produced a chronology of presence at the site, a written conclusion on whether the threshold had been crossed, and the attribution analysis the company would need for the years affected.
Case study 3
A subsidiary that did not shield its parent
A group assumed that incorporating a local company removed any question of the parent having its own taxable presence. In practice the parent's own staff continued to travel in, negotiate with the same customers and sign a share of the business directly, using the subsidiary's offices whenever they were there. We separated the two enterprises' activities: what the subsidiary did for itself, what it did for the parent, and what the parent did on its own account in that country. The engagement produced a written position on the parent's presence, an intercompany services agreement covering the work the subsidiary was really doing, and attribution papers for the parent's direct business.
Case study 4
Rebuilding branch profit attributed without a functional analysis
A branch had returned a fixed margin on its costs for several years, adopted when it was opened and never revisited. By the time we saw it, the staff were negotiating terms and carrying customer credit. We prepared the analysis the attribution had always lacked: functions performed in the branch, assets used, risks controlled by the people there, and the dealings with the rest of the enterprise that followed from them. The engagement produced a revised attribution basis, a written record of the functional profile, and a note of the years for which the earlier figure would be hard to sustain.
Case study 5
Documenting a no-presence position before an audit rather than after
A group with staff travelling regularly into one country wanted its position on paper while the facts were still fresh. We gathered the travel records, the customer meeting notes, the authority granted in each employment contract, and the terms on which group members used each other's offices. Two roles were reclassified as a result, and one office arrangement was put on a written licence rather than an informal understanding. The engagement produced a contemporaneous file setting out the conclusion and its basis, and a short list of the practices that would change the answer if they drifted.
Case study 6
Relief where two countries disagreed about the presence
One state assessed business profits on the footing that a presence existed; the other declined to relieve the tax, taking the view that none did. The enterprise was taxed twice on the same profit. We prepared the factual record both administrations would work from, set out how each had characterised the same arrangement, and identified the article under which the disagreement had to be settled. The engagement produced a documented double-taxation position and a mutual agreement request, with the supporting analysis each competent authority asked to see.
Case study 7
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.
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Case study 8
Social Security Contributions Owed in Two Countries at Once
A totalization agreement assigns contributions to one system and exempts the other, but only against a certificate obtained in advance. Without it both sets come out of the same salary and neither is straightforward to recover.
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