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The question is about taxation.

2. Pacific Enterprises Ltd ("Pacific") is a company incorporated and tax resident in Country A. It carries on a contract manufacturing business in Country A. The management of Pacific has ambitious plans to expand its operations by significantly increasing the efficiency of its contract manufacturing operations, and thereby, its overall competitiveness. The management of Pacific has a longstanding relationship with BIG Consulting, which specializes in consulting to contract manufacturers. BIG Consulting is a very large consulting firm with subsidiaries in many countries. To date, the engagements between Pacific and BIG Consulting have been entered into between Pacific and BIG Consulting Country B Ltd ("BC"), a company incorporated and tax resident in Country B. A senior consultant (Ms. Smith) was seconded to Pacific to temporarily perform the role of Chief Operating Officer. The secondment began on 1 October 2019; and is expected to run for at least 12 months. During the period of the secondment: Ms. Smith remains an employee of BC. BC continues to pay her compensation, being her salary, bonus, and secondment allowances. Required: Please advise BC whether it would have a Fixed Place of PE in Country A as the result of its activities under the engagement described above

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