Results 251 to 260 of about 789,798 (311)
Some of the next articles are maybe not open access.
Children and Young People Now, 2023
New practice standards aim to support social care organisations to develop early permanence
openaire +1 more source
New practice standards aim to support social care organisations to develop early permanence
openaire +1 more source
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
openaire +1 more source
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.
openaire +1 more source
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.
openaire +1 more source
Agency Permanent Establishments
International Transfer Pricing Journal, 2010Part of the Comparative Survey. The French Supreme Administrative Court recently decided in the Zimmer case that a French subsidiary of a foreign parent company, which operated in France under French law as a commissionaire, did not constitute a taxable French permanent establishment in France of the foreign company. The case has
S.G. Andresen, E. Furuseth
openaire +1 more source
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
openaire +1 more source
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”.
openaire +1 more source
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.
openaire +1 more source
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 ...
openaire +3 more sources