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4.1. Domestic PE of a Foreign Entity

Gibraltar assesses companies to tax regardless of their residence on income accrued in or derived from Gibraltar. A foreign company will be deemed to meet this test if it is licensed to carry on business (e.g. financial services, gaming or trading license) in Gibraltar or is otherwise deemed to have a permanent establishment (PE) therein. Ordinarily, the PE threshold requires the existence of human resources and management in Gibraltar. A ruling confirming whether or not a given business activity represents a PE in Gibraltar may be sought from the authorities.