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Atlasposting – Permanent Establishment Risk Analysis as construction site

A tax analysis aimed at identifying the risk of a construction-site permanent establishment, with the preparation of a professional opinion and dedicated dossier.

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since 1998

Studio A&P offers professional consulting services to businesses and individuals.

Studio A&P supports companies and individuals with their activities in Italy and Worldwide, providing specialized assistance in global mobility of workers, Italian and international taxation.

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A&P in 2025
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We are providers for:

For companies operating abroad

Who can benefit from the service

This service is designed for companies that carry out construction activities outside their home country.

Arletti & Partners Team

The team at Studio Arletti & Partners is made up of over 50 highly qualified and multilingual professionals, specialized in global mobility and tax consultancy, including worker postings, Italian and international taxation, and immigration procedures both in Italy and abroad.

Our Areas of Expertise include:

Tax assessment of the permanent establishment risk

Permanent establishment risk analysis

The software monitors the duration of the company’s presence on a construction site in a foreign country. Based on international tax treaties, it can identify whether a risk of permanent establishment exists—requiring a further compliance analysis for the company.

Where the monitoring and risk alerts occur

Where to monitor the risk

During the registration of a construction site, the system automatically checks the duration of the activity. Based on the recorded days, the dedicated area will display a risk alert for a potential Permanent Establishment according to the bilateral treaty between the countries involved, making a risk analysis necessary.

Automatic alert when the threshold is exceeded

When the Permanent Establishment risk alert is triggered

The system issues an alert and recommends a Permanent Establishment risk analysis when the construction site exceeds the time limits set by bilateral treaties, which could establish the conditions for a Permanent Establishment.

Ensuring compliance when a Permanent Establishment is identified

Compliance in case of Permanent Establishment

Failure to register a Permanent Establishment when the conditions are met may result in civil, tax, and—if the unpaid taxes exceed certain thresholds—even criminal penalties.

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