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The Permanent Establishment: Still a (Permanent) Requirement?
EC Tax Review, 2014This article examines the relevance of the 'remaining permanent establishment' requirement under the Merger Directive in the light of the recent jurisprudence of the Court of Justice of the European Union on corporate exit taxes. This requirement is a mechanism meant to ensure that Member States will be able to effectively exercise their taxing rights.
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Business Restructuring and Permanent Establishments
International Transfer Pricing Journal, 2010This article outlines two common forms of business restructuring involving the conversion of manufacturing and distribution entities; and, by way of analysis of the permanent establishment articles in bilateral treaties that entered into force between 1 January 2008 and 31 December 2009, considers permanent establishment risks associated therewith.
J.L. Cooper, S.B. Law
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The taxation of permanent establishments
Asia-Pacific Tax Bulletin, 2009A practical insight on the taxation of permanent establishments under the new corporate income tax law.
N. Nguyen, C. Llanes Navarro
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Key issues relating to permanent establishments
Asia-Pacific Tax Bulletin, 2009The author discusses a number of key issues that relate to the permanent establishment concept.
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How “Permanent” Should a “Material Permanent Establishment” Be?
European Taxation, 2009In this note, the author considers the implications of a recent Belgian tax case regarding permanent establishments (PEs), with particular reference to the concept of a “material permanent establishment”.
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The Concept of Permanent Establishments
European Taxation, 2014The PE concept plays a prominent role in the tax treatment of cross-border business activities and is relevant to the application of domestic tax law and tax treaties. These two areas of law, however, do not use the same PE definition. This article analyses the PE definition under Luxembourg domestic tax law and for tax treaty purposes.
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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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Integrative oncology: Addressing the global challenges of cancer prevention and treatment
Ca-A Cancer Journal for Clinicians, 2022Jun J Mao,, Msce +2 more
exaly
Digital business and permanent establishment
2018Die Digitalisierung ist ein wachsendes Phänomen unserer modernen Wirtschaft. Traditionelle Unternehmen werden mehr und mehr durch digitale Unternehmen verdrängt. Das grenzüberschreitende Verschieben von Vermögen und die Fragmentierung von Tätigkeiten erlauben multinationalen Unternehmen das Vermeiden von Betriebsstätten und somit Besteuerung.
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