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SILVERSIX ConsultantTax & Business Advisory
International Tax · Professional Utility

PE Exposure Risk Calculator

Screen a cross-border operation for permanent-establishment risk — fixed place, agency, service and construction PE triggers — and get a Low / Medium / High rating with the drivers flagged.

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Questionnaire

PE risk score

Risk drivers & notes

Screening tool only. PE determination depends on the specific facts, the applicable tax treaty (Articles 5 & 7), domestic law and the MLI. A high score signals areas to examine, not a conclusion that a PE exists. Obtain a considered opinion before taking a position.