Madagascar

Corporate - Corporate residence

Last reviewed - 04 February 2020

Companies are considered resident in Madagascar if they are registered in Madagascar or have a legal existence in Madagascar.

Permanent establishment (PE)

PE refers to a fixed place of business through which a company carries out the whole or part of its activities, including:

  • Management offices.
  • Branches.
  • Offices.
  • Factories.
  • Workshops.
  • Mining sites, oil or gas wells, quarries, or any other places for the extraction of natural resources.
  • Building sites, construction or installation projects, or supervising activities lasting for more than six months in relation to those projects.
  • Provision of services by a company, including advisory services, via employees or other staff hired by the company to this end, only if such activities are carried out in Madagascar for a total period of 183 days for a 12-month period either starting or ending during the fiscal year involved, for the given or a related project.

PE does not include:

  • The use of facilities for the storage or display of goods or merchandise belonging to the company.
  • Exploiting a stock of goods or merchandise belonging to the company for the sole purpose of either storage or display or of being processed by another company.
  • Exploiting a fixed place of business for the sole purpose of:
    • either purchasing merchandise or collecting information for the company
    • carrying out any other activity of preparatory or auxiliary character for the company, or
    • pursuing any combination of the activities mentioned above, conditional on the overall activity of the fixed place of business, as resulting from this combination, remaining of preparatory or auxiliary character.