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What is Permanent Establishment (PE) Risk?

Lexicon Entry: Article 14 Nexus Analysis

Feb 17, 2026
6 min read
Arakan Statutory Team

**Permanent Establishment (PE)** is a concept used to determine if a foreign entity has a sufficient "Fixed Place of Business" in the UAE to be subject to Corporate Tax.

Forensic Indicators of PE

Under Article 14, PE risk is triggered by "Fixed Places" or "Dependent Agents." In the digital era, the FTA looks for:

  • **Digital Nexus:** Servers or habitual local decision-making.
  • **Dependent Agent:** A person in the UAE who habitually exercises authority to conclude contracts on behalf of a foreign entity.