Macau SAR

Corporate residence is generally determined by reference to the place of establishment.

Permanent establishment (PE)

There is no specific definition of PE in the Macau Complementary Tax Law. Technically speaking, there are two major criteria for determining whether a foreign entity should be subject to complementary tax, and the key phrases are 'engaging in commercial/industrial activities' and/or 'rendering services in Macau SAR'. These phrases are also not defined. Generally, if a foreign entity is engaged in commercial/industrial activities and/or rendering services in Macau SAR, the resultant gain from such commercial/industrial activities and/or services rendered will be subject to complementary tax.