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4.1. Domestic PE of a Foreign Entity

Central African Republic is a member state of CEMAC and PE is defined under the tax convention applicable to the member states of CEMAC. Accordingly, PE is defined as a place of management of the activities of a foreign entity including the following:

  • a management seat;
  • a branch;
  • a desk;
  • factory;
  • a workshop;
  • a mine, quarry or other place of extraction of natural resources;
  • a construction or assembly site;
  • an installation used for storage purposes, exhibition or delivery of goods owned by the company;
  • a warehouse of goods belonging to the company, stored for storage, delivery show;
  • a fixed place of business used for the purposes to buy goods.

However, following places are not considered as PE of a foreign entity:

  • goods belonging to the company stored for the sole purpose of processing by another company; and
  • a fixed place of business used for the sole purpose of preparatory or auxiliary services in respect of advertising, supply information, scientific research or similar activities.

The tax convention applicable to the CEMAC member states does not specifically include in its PE definition, the constitution of service PE on the completion of a specified number of days.