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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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The Tax Treatment of Permanent Establishments
European Taxation, 2014In an article published in European Taxation 4 (2014), the author outlined the differences between the permanent establishment concept under Luxembourg domestic law and that applicable for tax treaty purposes. This article builds on this discussion, focusing specifically on the tax treatment of permanent establishments under Luxembourg tax law and ...
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Attribution of Profits to a Permanent Establishment
Asia-Pacific Tax Bulletin, 2019The Indian government has recently released a discussion draft report on Attribution of Profits to PE. The report is of significant importance and represents an important development in international taxation. It takes into consideration the approach of the OECD, European Union and United States on attribution of profits and recommends changes to the ...
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The Profits Directly or Indirectly Attributed to a Permanent Establishment
Journal of Tax and Business, 2021Gunadi Gunadi
exaly
The attribution of profits to permanent establishments
Weekblad voor Fiscaal Recht, 2006IFA ...
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