1. Purpose
This policy sets out how Murzo Group manages permanent establishment risk, local entity decisions, overseas tax presence, representative offices, branches, subsidiaries, warehouses, and foreign operational footprints.
The purpose is to prevent accidental foreign tax residence, undeclared taxable presence, local registration failures, hidden payroll duties, and unmanaged authority exposure.
2. Scope
This policy applies to overseas offices, warehouses, property, farms, showrooms, storage, local staff, dependent agents, distributors, local representatives, remote workers, secondments, project sites, fulfilment centres, and repeated overseas business activity.
3. Permanent Establishment Risk
Murzo Group must consider permanent establishment and local tax presence before creating a fixed place of business, appointing a person who habitually concludes contracts, storing goods for local sale, carrying out long-term projects, or placing staff in another country.
Tax treaties, domestic law, and local authority practice can differ. The same activity may be low-risk in one country and high-risk in another.
- Fixed office, workshop, farm, facility, warehouse, showroom, or place of management
- Local staff, secondees, contractors, or dependent agents
- People negotiating, concluding, or materially finalising contracts overseas
- Goods stored, assembled, repaired, distributed, or fulfilled locally
- Repeated installation, construction, inspection, design, or client delivery projects
- Overseas directors, board activity, banking, or management decisions
4. Local Entity Decisions
Murzo Group may operate through a UK company, branch, subsidiary, local company, representative office, distributor, agent, joint venture, or other structure depending on legal, tax, commercial, regulatory, and risk considerations.
A local entity should not be created merely for convenience. It should have a clear purpose, authority, governance model, funding basis, tax position, local filings, banking controls, and exit plan.
5. Overseas Property and Facilities
Acquiring, leasing, occupying, or using property overseas can create local tax, employment, health and safety, environmental, licensing, insurance, and permanent establishment issues.
This policy should be read alongside the Real Estate Acquisition, Leasing & Facilities Management Policy and the Land, Soil, Water & Environmental Stewardship Policy.
6. Approval Requirements
The following should receive senior approval and appropriate professional input before commitment.
- Opening a branch, subsidiary, office, farm, warehouse, showroom, or local bank account
- Hiring, seconding, or engaging people overseas
- Appointing an agent with authority to negotiate or conclude contracts
- Holding stock overseas for local sale or fulfilment
- Entering long-term local projects or local service delivery
- Registering for local VAT, payroll, corporate tax, social security, or licensing
7. Required Evidence Only
Tax, corporate, authority, adviser, contract, and approval evidence should be limited to what is required by law, contract, authority request, audit, or operational need.
8. Review
This policy will be reviewed when Murzo Group starts sustained activity in a new country, changes overseas staffing or warehousing, appoints local agents, or creates or closes a foreign entity.
