4.1. Domestic PE of a Foreign Entity
A permanent establishment is not defined under the tax Laws of Macau.
Generally, non-resident entities carrying out commercial or industrial activities or rendering services in Macau are subject to corporate income tax, known as ‘complementary tax’ in Macau.
Further, the tax treaties entered into by Macau with Mozambique and Vietnam provide specifically for service PE, which requires the physical presence of employees or personnel of the non-resident company for a prescribed period in Macau. Certain tax treaties (e.g., the treaty with Portugal) do not contain a specific service PE clause.