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The Future of the Permanent Establishment Concept
Bulletin for International Taxation, 2018In this article, the author evaluates whether the amendments proposed by the OECD/G20 BEPS Initiative effect the permanent establishment threshold to become economic in nature rather than one based on physical presence. In doing so, the author considers the future of the permanent establishment concept.
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New Trends in the Definition of Permanent Establishment
2019New Trends in the Definition of Permanent Establishment, comprising the proceedings and working documents of the annual seminar held in Milan in November 2018, is a detailed and comprehensive study on the definition of permanent establishment (PE). It begins with an overview of article 5 of the OECD Model Convention, focusing on the history of that ...
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The taxation of permanent establishments in Canada
Bulletin for International Taxation, 2009This article examines some of the main features of Canada's tax laws and policies regarding the taxation of permanent establishments (PEs). The article discusses the definition of PE in Canada's tax treaties and sets out the tax laws and policies on agency PEs and the PE fiction permitting the taxation of non-resident entertainers and athletes.
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International Taxation of Permanent Establishments
2011The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments.
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Italy: is there a permanent establishment?
2016The author in this chapter of the book analyzes the Supreme Court decision No. 5649 delivered on 20 March 2015 which deals with the existence of a permanent establishment (PE) (stabile organizzazione occulta) in Italy of a non-resident company.
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The taxation of permanent establishments in the Netherlands
2014overzicht van de fiscale behandeling van vaste inrichtingen in ...
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