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4.2. Domestic PE of a Foreign Entity

Bolivian domestic law does not define the terms permanent establishment. This is mainly due to the prevailing territorial system under which any income sourced in Bolivia is taxable therein, whilst any profits derived from foreign sources are not taxable in Bolivia. Although the term permanent establishment itself is not defined by the law, it is expressly included in the definition of the term "enterprise" and therefore subject to corporate income tax (IUE).

With the exception of Argentina and Andean Community, the tax treaties entered into by Bolivia define permanent establishment (PE) as a "fixed place of business through which the business of an enterprise is wholly or partly carried on"