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Australia: Guide on taxation of permanent establishments (PEs)

ATO guide explains tax rules for permanent establishments in Australia and abroad.

june 25, 2026

The Australian Taxation Office (ATO) has released a guide that outlines how tax applies to permanent establishments (PEs) in Australia and overseas.

The guide outlines:

  • What is a PE
  • Whether nonresident enterprises can be taxed in Australia
  • How profits attributed to a PE will be calculated
  • Where Pillar Two top-up tax may apply

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