The place of incorporation is regarded by Honduran authorities as the corporate residence. Non-resident companies are companies incorporated/registered outside of Honduras.
Permanent establishment (PE)
There is a provision in the transfer pricing rules that provides the following definition of PE:
“Permanent establishment is a fixed place of business where a natural or juridical person resident or domiciled in another state performs part or all of its activities in Honduras. Likewise, a foreign resident will be considered to have a permanent establishment in Honduras when it acts in the national territory through an independent agent that is not acting under the regular framework of its activity."
There are some exceptions to the rule.
There is no treaty definition of PE since, at the present time, Honduras is not a signatory of any double taxation treaty (DTT) with another jurisdiction in the world.