10.24

Cyprus PE Risk Analysis for Tech Company Employee Relocation

PE Risk Assessment for International Tech Group with Employee in Cyprus


Our Work

We undertook a project to advise on, prepare, and submit an Advanced Tax Ruling request to the Cyprus Tax Department on behalf of a client, an international technology services company, regarding the risk of creating a Permanent Establishment (PE) in Cyprus due to the permanent relocation of one of its employees. Our analysis focused on the Cyprus–France Double Tax Treaty and Cyprus tax law, concluding that the employee’s activities are preparatory and auxiliary in nature, meaning they do not trigger tax obligations for the company in Cyprus. Additionally, we advised the client on its employer obligations arising from having an employee in Cyprus, ensuring full tax compliance.