CFO Insights Emma Game, Partner at Wilson Sonsini, discusses common tax related considerations for CFOs in Tech
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Dec 16, 2025 
Emma Game, a Partner at Wilson Sonsini in London, specializes in tax advice for high-growth startups. She breaks down key tax considerations for CFOs in tech, including permanent establishment risks and when VAT/sales tax applies. Emma emphasizes the importance of reviewing corporate tax exposure as companies expand internationally and highlights common pitfalls during acquisitions. She also clarifies misconceptions around employer-of-record arrangements and the need for effective coordination between finance and sales teams to ensure tax compliance.
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Permanent Establishment Is The Core Expansion Risk
- Permanent establishment (PE) risk is the central tax concern when scaling internationally and can create corporate tax liabilities abroad.
- Early-stage decisions that ignore PE can grow into material exit issues with interest, penalties, and buyer price chips.
Keep PE Reviews Proportional And Ongoing
- Regularly review your PE position as headcount and activities evolve and don't rely on a one-time assessment.
- Define trigger points (seniority, revenue-generating roles, office space, team size) to prompt deeper tax review.
Control Contracting Authority Abroad
- Track who signs or habitually concludes contracts abroad and limit authority if you want to reduce PE risk.
- Reorganise sales processes so local employees do not habitually conclude contracts in the foreign jurisdiction.