Tax treaty override in Slovakia - Digital platform permanent establishment
Bratislava Law Review, 2018 The article analyses the new “digital platform permanent establishment” concept as a legal fiction establishing a fixed place even in situations where there is no actual fixed place.
Tomáš Cibuľa, Matej Kačaljak
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The Multilateral Instrument: Avoidance of Permanent Establishment Status and the Reservations on behalf of Australia and the UK [PDF]
, 2013 This paper considers fully probabilistic system models. Each transition is quantified with a probability—its likelihood of occurrence. Properties are expressed as automata that either accept or reject system runs. The central question is to determine the
Ivanova, Milla
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A critical analysis of the concepts ‘Permanent Establishment’ and ‘Foreign Business Establishment’
Journal of Economic and Financial Sciences, 2012 The objective of this study was to analyse and compare the concepts permanent establishment and foreign business establishment in order to make recommendations regarding the required additions and amendments to replace the concept foreign business ...
Linda van Schalkwyk, Rozelle van Schaik
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Aspek Hukum Subyek Pajak Bentuk Usaha Tetap Menurut Hukum Positif di Indonesia
Binus Business Review, 2010 PE (Permanent Establishment) is an international tax terminology which is a consequence of the operations of the base/fixed sites in the treaty partner country, after fulfilling certain conditions stipulated in the Tax Treaty or the Act, such as: types ...
Paulus Aluk Fajar Dwi Santo
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Determining the Right Tax Jurisdiction in Bilateral Taxation Treaties and Preventing Abuse of the "Permanent Establishment" Concept [PDF]
Faṣlnāmah-i Pizhūhish-i Huqūq-i ̒Umūmī, 2016 Bilateral tax treaties in the world are significantly spreading as a tool for waiver of double taxation, which is an obstacle in the way of expansion of international trade.
Gholam Nabi Feyzi Chekab +1 more
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A novel spherical actuator: Design and control [PDF]
, 1997 The paper describes the design and control of a novel spherical permanent magnet actuator which is capable of two-degrees-freedom and a high specific torque. Based on an analytical actuator model, an optimal design procedure is developed to yield maximum
Howe, D., Jewell, G.W., Wang, J.B.
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A Review of Factors to Consider for Permanent Cordon Establishment and Maintenance
Agronomy, 2021 Decisions made during the establishment and reworking of permanent cordon arms may have long-term consequences on vineyard health and longevity. This review aims to summarise several of the important considerations that must be taken into account during ...
Patrick O’Brien +3 more
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Theoretical and Practical Assessments of Transfer Prices. Legal Evidence from Romanian Case Law
Journal of Legal Studies, 2020 Transfer pricing represents the mainstream agenda in the light of tax law, lato sensu, and international taxation, stricto sensu. At the international level, there can be an emphasis on several problems related to taxation: double taxation, double non ...
Dumiter Florin Cornel +1 more
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The Indian Journal of Agricultural Sciences, 2021 The experiment was conducted during 2018-19 and 2019-20 at ICAR-IARI research farm, to see the effect of crop establishment and nutrient management options on growth and yield of wheat under maize-wheat system.
MOHAMMAD HASANAIN +7 more
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Taxation of Permanent Establishments in Ukraine: Unresolved Issues
Kyiv-Mohyla Law and Politics Journal, 2018 This article deals with selected issues of taxation of permanent establishments in Ukraine that lack appropriate judicial and scholarly attention.
Vitalii Trachuk, Khrystyna Franchuk
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