Question
Equipment AG is incorporated and managed in Germany. It sells manufacturing equipment to persons in Mauritius. The equipment comes with a two year warranty. Equipment
Equipment AG is incorporated and managed in Germany. It sells manufacturing equipment to persons in Mauritius. The equipment comes with a two year warranty. Equipment AG sets up a repair workshop in Mauritius. The workshop carries out repairs under warranty on equipment sold by Equipment AG. No charge is made for these repairs. It also carries out repairs on the equipment outside the warranty period, and charges cost plus 20% for this service. The employees of the workshop also regularly buy components from manufacturers in Mauritius which are then shipped to head office in Germany. Head office attributes a buying commission of 5% on these components to the workshop when preparing its management accounts to ascertain the profitability of its various operations. Required: Does Equipment AG have a permanent establishment in Mauritius? If so, what profits are taxable there? (5 marks)
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