1. Installation of Equipment or Machinery:
   • A permanent establishment (PE) is created when a non-resident person installs or uses substantial equipment or machinery in Ghana. This physical presence for a significant duration or scale constitutes a PE.
2. Provision of Services:
   • If a non-resident person provides services within Ghana for an extended period, typically more than 183 days within any 12-month period, a PE is created. The non-resident will be subject to tax on the income earned from these services.
3. Construction or Installation Project:
   • A non-resident person engaged in a construction, installation, or assembly project in Ghana, or supervising such projects, establishes a PE if the project lasts for more than 6 months. The income from such projects will be taxed in Ghana.
4. Agency Relationship:
   • When a non-resident person operates through a dependent agent in Ghana who has the authority to conclude contracts on their behalf, a PE is created. The agent’s activities will subject the non-resident to tax in Ghana, except if the agent is independent and acts in the ordinary course of their business.

Taxation of Permanent Establishment in Ghana:

• Income attributable to the PE will be subject to corporate tax at the applicable rate (e.g., 25%). Additionally, the PE may be subject to withholding tax on payments and required to file tax returns and register for a Taxpayer Identification Number (TIN) in Ghana.