Structuring permanent establishments and tax treaties with certainty

A permanent establishment or subsidiary gives rise to immediate compliance obligations that take many companies by surprise. The tax qualification has far-reaching consequences for registration obligations, profit attribution and the tax burden. For international groups, we analyse these risks at an early stage and create clear bases for decision-making.

PDC - Vieider Zanellato Lanznaster Pichler Gasteiger

Tax treaty matters & permanent establishments

PDC - Vieider Zanellato Lanznaster Pichler Gasteiger

Tax treaty matters & permanent establishments

Avoiding double taxation, gaining planning certainty

Tax treaties between Italy and other countries offer considerable structuring potential – provided they are applied correctly. We advise on treaty application, on the tax planning of inbound and outbound structures and on the attribution of profits between head office and permanent establishment. In doing so, we take into account Italian tax law as well as the generally recognised OECD principles and the applicable EU provisions.

Agency and construction site permanent establishments, tax registration obligations in Italy or the distinction between subsidiary and permanent establishment require careful tax planning. The focus lies on legally secure structuring and the consistent attribution of profits and income in an international corporate context.

Your contacts

Dott. Comm. Josef Vieider

Dott. Comm. Alessandro Zanellato

Dott. Comm. Stefan Lanznaster

Dott. Comm. Thomas Pichler

Dott. Comm. Sabrina Tabiadon

Newsletter

Our newsletters – Useful Updates on Tax and Legal Matters

13.08.2026, Newsletter No. 35/2026

Corrective decree to the tax reform of 7 August 2026 – other changes

Legislative Decree No. 148 of 7 August 2026 introduces numerous further corrections to the tax reform – from income from employment to business and financial income, from VAT to tax assessment and the two-year advance agreement.

12.08.2026, Newsletter No. 34/2026

Corrective decree of 7 August 2026 and its effects on the mixed use of company cars

The corrective decree of 7 August 2026 (Legislative Decree No. 148/2026) standardises the calculation of the benefit in kind for the mixed use of company cars with retroactive effect from 1 January 2026 and at the same time introduces two new surcharges on the benefit-in-kind value.

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