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Cases · Tax, finance & assurance · International tax planning & transfer pricing

Decide when sales require a local entity

At what point do our sales abroad mean we need a local company?

WONE Global reviews your activity against the tax and corporate thresholds in each market and tells you when, and how, to register.

Countries in the typical case Canada · Germany

The situation

What is happening

What is at stake

Selling too long without registering can create a permanent establishment and back taxes; registering too early adds cost.

A scenario

Software companyFounder-led company · from Canada · in Germany

Its salesperson in Germany has started signing contracts, which may make the company taxable there.

Where it ends A clear tax position in Germany.

A representative scenario of the work WONE Global coordinates, not a specific client’s matter.

Also asked as “Are we creating a taxable presence abroad?”“Can we keep selling from home without registering locally?”“Our overseas sales model could create taxable presence”

The solution

How WONE Global handles it

WONE Global reviews your activity against the tax and corporate thresholds in each market and tells you when, and how, to register.

Usually led by Tax and structuring, with Setting up and running a company and Contracts and commercial law.

Step by step, in the scenario

  1. Day 1WONE Global reviews the role against German tax rules.
  2. Week 1Options: change the role, register or incorporate.
  3. Week 2Chosen option put in place.
  4. ThenPast position reviewed.

Timings are typical. They depend on the countries, the authorities involved and how quickly documents are available.

Decisions

The decisions involved

  1. 01When sales activity creates a taxable presence
  2. 02Licensing or contracting rules that require local presence
  3. 03The cost and benefit of a local entity vs staying cross-border

Outcomes

What you receive

  • A permanent-establishment risk review
  • Thresholds and triggers to monitor
  • A recommendation and timing for local presence

This is a general guide. Your WONE Global professional confirms the work, timing and fees for your markets before anything starts.

Services

The services involved

One area of expertise usually leads; the others move with it. WONE Global keeps them connected across every country involved.

  1. Usually leadsTax and structuring17 markets with a named lead→
  2. Often involvedSetting up and running a company3 markets with a named lead→
  3. Often involvedContracts and commercial law12 markets with a named lead→

Who handles it

Tax and structuring, market by market

The status of the lead service in the markets that matter for this case. A named WONE Global Partner acts under their own licence; where none is in place yet, WONE Global confirms availability before anything else.

  1. Germanyin the typical case WONE Global Partner Ulrike Berner, MBA · Managing Partner Brief this Partner →
  2. Canadain the typical case On request Availability confirmed before any work begins Bring a requirement →
  3. Austria WONE Global Partner Dr. Rosam Karl J. · Managing Director Brief this Partner →
  4. Cameroon WONE Global Partner Edmond Christian AKOA MBALLA · Founder & Managing Partner Brief this Partner →
  5. Colombia WONE Global Partner Katherin Diaz Velilla · Co-Founder Brief this Partner →
  6. Ecuador WONE Global Partner Mauro Tejada Ramon · Tax & Legal Partner Brief this Partner →
  7. Hong Kong WONE Global Partner Yvonne Chow · Partner Brief this Partner →
  8. India WONE Global Partner Sandeep Gupta · Managing Partner Brief this Partner →
  9. Ireland WONE Global Partner Kevin McSharry · Managing Director Brief this Partner →
  10. Italy WONE Global Partner Alessandro Dagnino · Managing Partner Brief this Partner →
  11. Kenya WONE Global Partner Farheen Khandwalla · Tax and Business Process Outsourcing Partner Brief this Partner →
  12. Panama WONE Global Partner Ebrahim Asvat K. · Managing Partner Brief this Partner →
  13. Rwanda WONE Global Partner Lilianne Gasango · Tax & Financial Advisor Brief this Partner →
  14. Saudi Arabia WONE Global Partner Abdullah Yousef Alhussaini · Founding Partner Brief this Partner →
  15. United Arab Emirates WONE Global Partner Priju Dominic · CEO & Founding Partner Brief this Partner →
  16. United States WONE Global Partner F Miles Adler · Principal Brief this Partner →
  17. Vietnam WONE Global Partner Chau Kim Hien · CEO Brief this Partner →
  18. Zambia WONE Global Partner Gerald Zimba · Director Brief this Partner →
  19. Singapore On request Availability confirmed before any work begins Bring a requirement →
  20. United Kingdom On request Availability confirmed before any work begins Bring a requirement →

Other markets: WONE Global covers 100 countries. Name yours in the requirement →

Katherin Diaz VelillaBogotá · Colombia

WONE Global Capability Partner · Colombia

Katherin Diaz Velilla

Complete profile

Co-Founder · V&V Associates · Bogotá

International tax attorney and strategic advisor with 12+ years across Colombia's DIAN, Ministry of Finance, Senate, Presidency, and EY. Co-founder of V&V Asociados. Specializes in cross-border tax structuring, transfer…

Mauro Tejada RamonQuito · Ecuador

WONE Global Capability Partner · Ecuador

Mauro Tejada Ramon

Tax & Legal Partner · G&G Auditores Independientes & Lex Fiscal Corp · Quito

Professional with 20 years of experience in Tax Administration, performing functions in the managerial and tax administration fields. Experience related to the fiscal field in the main sectors of the economy: Banking, c…

Ulrike Berner, MBAMunich · Germany

WONE Global Capability Partner · Germany

Ulrike Berner, MBA

Managing Partner · BSP Berner Schaeffler & Partners GmbH · Munich

Ulrike Berner has been Managing Director and shareholder of BSP since 2021, leading the strategic direction, client relationships, and business development of the firm. She has extensive experience working with firms an…

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