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PETRUZZI Advisory
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Permanent Establishments

Key Takeaways

  • 01

    The November 2025 OECD update revisits the home office as fixed place of business.

  • 02

    Dependent agent PE post-BEPS Article 5(5) lowered the threshold to commercial reality.

  • 03

    Service PE under the UN Model differs from the OECD framing.

The Engagement

How an engagement runs.

  1. 01
    Inquiry

    A short conversation to understand what's on the file: the structure, the timeline, the existing advisors.

  2. 02
    Scoping

    A written scope and fee letter. Concrete deliverables, dates, and the answer to who reviews what.

  3. 03
    Analysis

    Substantive work delivered by Dr. Petruzzi personally. OECD-paragraph rigor; named cases; citeable conclusions.

  4. 04
    Recommendation

    A written opinion or report. Sets out the framework, the facts, the application, and the residual risk.

  5. 05
    Implementation Support

    Implementation, follow-up, and ongoing access as the matter develops. The engagement doesn't end at delivery.

Written and reviewed by

Dr. Raffaele Petruzzi

PhD · LL.M. · M.Sc. · Managing Director, WU Transfer Pricing Center · Member, UN Subcommittee on Transfer Pricing

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FAQ

Questions on permanent establishments.