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4.2. Domestic PE of a Foreign Entity

Under Cyprus tax law, a permanent establishment is defined as "a fixed place of business through which the business of an enterprise is wholly or partly carried on" and includes a place of management, a branch, an office, a factory, a workshop, a mine, and a building site or construction or installation project provided that it lasts for more than three months. Foreign entities which are deemed to have a permanent establishment in Cyprus are subject to tax in Cyprus on the profits of the permanent establishment.