Action 7 of the BEPS project centers on changes to the definition of permanent establishment that may result in unintended adverse tax consequences for profit sharing arrangements.

Contributing to clients’ success by accelerating tax deductions, increasing tax credits, reducing cash taxes and mitigating risks

Baker Tilly’s tax team contributes to clients’ success by accelerating tax deductions, increasing tax credits, reducing cash taxes and mitigating risks.

Baker Tilly’s international tax specialists understand global business needs and the importance of how domestic and overseas tax systems intersect. We effectively help manage your worldwide tax affairs.

BEPS Action 7: Preventing the artificial avoidance of permanent establishment status

Capitalization not required for payment to terminate management agreement prior to IPO

BEPS Action 7: Preventing the artificial avoidance of permanent establishment status

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Capitalization not required for payment to terminate management agreement prior to IPO