GonzoOpera
Registered User
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I need help with PE issue.
Its a foreign construction company that carries work in Ireland. Accordig to Double Taxation Treaty between that country and Ireland a construction site becomes PE only when work exceeds 12 months. That is not an issue but....
The company was working in Ireland for the period of 10 months and then they switched into another company from their group that carried work in Ireland for another 8 months.
Company A spent 10 months on one construction site in Ireland. Then they fired all their employees employed in Ireland and formed Company B (also located in a foreign state)
The next day Company B hired all employees previously employed by Company A and continued work for another 8 months.
Both companies were an equivalent of Irish LTD so they have separate legal entity (same owner though)
Since they have the same owner and management they would form something called a Group am I correct?
Would then an entire group be counted as of time present in Ireland or each company separately as they are different legal entities regardless of ownership?
Its a foreign construction company that carries work in Ireland. Accordig to Double Taxation Treaty between that country and Ireland a construction site becomes PE only when work exceeds 12 months. That is not an issue but....
The company was working in Ireland for the period of 10 months and then they switched into another company from their group that carried work in Ireland for another 8 months.
Company A spent 10 months on one construction site in Ireland. Then they fired all their employees employed in Ireland and formed Company B (also located in a foreign state)
The next day Company B hired all employees previously employed by Company A and continued work for another 8 months.
Both companies were an equivalent of Irish LTD so they have separate legal entity (same owner though)
Since they have the same owner and management they would form something called a Group am I correct?
Would then an entire group be counted as of time present in Ireland or each company separately as they are different legal entities regardless of ownership?