Püsiv tegevuskoht käibemaksu kontekstis

49 869 vastust

EL maksuõiguse mõju Eesti käibemaksuseadusele

Rahandusministeeriumi väljaantud käibemaksuseaduse kommenteeritud väljaandes (http://www.fin.ee/index.php?id=280) on eelnevatest printsiipidest lähtuvalt püsivat tegevuskohta iseloomustatud inimressursside ja tehniliste vahendite piisavalt püsiva ja sobiva struktuurina, mis võimaldab sellel tegevuskohal võõrandada kaupu ja osutada teenuseid.

Seega, kui teenuse saajana on mitteresidendil käibemaksu osas Eestis püsiv tegevuskoht olemas, aga see Eesti struktuur ise teenuseid ei osuta (st maksustatav käive puudub), kohaldatakse isiku suhtes samu sätteid kui välisriigi isiku suhtes, kellel puudub Eestis püsiv tegevuskoht.

Kirjeldan kahte olukorda, kus püsiv tegevuskoht tekib kas ainult käibe- või tulumaksu kontekstis.

Esinduskontor kui püsiv tegevuskoht vaid käibemaksu mõistes

Näiteks võib mitteresidendil Eestis olla äriregistris registreeritud filiaal,  mis sisuliselt täidab esinduskontori funktsiooni (täidab mitteresidendi kogu äritegevust silmas pidades vaid ettevalmistavat ja abistavat funktsiooni ega tegele otseselt müügiga) ja seega ei tekita püsivat tegevuskohta tulumaksuseaduse ja rahvusvaheliste maksulepingute kontekstis. Küll aga saaks sellist kontorit vaadelda teenuse saajast püsiva tegevuskohana käibemaksu kontekstis eeldusel, et esinduskontori inim- ja tehniline ressurss võimaldab saada ja kasutada enda tarbeks teenuseid (maksustatava käibe tekkimisel tuleks maksukohustuslasena registreerimise osas juhinduda käibemaksuseaduse § 19 lõikest 1).

Agent kui püsiv tegevuskoht vaid tulumaksu mõistes

Vastupidise näite puhul, kui mitteresidendi nimel teostab Eestis kõiki tehinguid Eestis asuv ettevõtja, näiteks agendilepingu alusel ning mitteresidendil endal ei ole Eestis majandusüksust (tegevuskohta), mille kaudu ta teostaks siin ettevõtlust, siis ei ole tal tekkinud Eestis püsivat tegevuskohta käibemaksu osas. Samas, mitteresidendi nimel lepinguid sõlmima volitatud esindaja kaudu Eestis toimuva majandustegevuse tulemusena tekib tõenäoliselt püsiv tegevuskoht tulumaksuseaduse ja rahvusvaheliste maksulepingute kontekstis.

Sigrid Polli

=> raamatupidaja.ee – Püsiv tegevuskoht käibemaksu kontekstis.

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