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BRICS Law Journal, 2022 The digitalisation of the economy has created a number of complex problems in the area of taxation. A majority of these problems relate to the issue of the distribution of taxing rights between states in the context of taxing income received as a result ...
K. Ponomareva
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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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NGOs and the UN Security Council: Between informal reality and possibilities of formal interaction [PDF]
The Review of International Affairs, 2021 Following the end of the Cold War, non-governmental organizations (NGOs) took the initiative in their interactions with the UN Security Council. Since then, mechanisms for informal consultations between NGOs and the Security Council have been established.
Jelica Gordanić
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The permanent establishment concept under tax treaties and its implications for multinational companies [PDF]
This dissertation explores the concept and implementations in practice of permanent establishment(PE) introduced by Article 5 in the OECD Model Income Tax Treaty, highlighting the implications and ambiguities for multinational companies and nation state ...
Nakayama, Aiko
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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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Social Integration of the Former Transcarpathian Students of the Balassi Institute
Central European Journal of Educational Research, 2020 In the present study, we examine the social integration of former Transcarpathian students who participated in the university preparatory training of the Balassi Institute. Social integration plays a major role, both among mobile students settling in the
Katalin Pallay
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New Trends in the Definition of Permanent Establishment: The Netherlands
, 2019 This paper elaborates on current and emerging issues involving the operation of the concept of permanent establishment (PE) in the national tax system and double tax treaty system of the Netherlands.
Wisman, C, de Wilde, Maarten
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Critical analysis of the concepts 'permanent establishment' and 'foreign business establishment' [PDF]
, 2012 CITATION: Van Schalkwyk, L. & Van Schaik, R. 2012. Critical analysis of the concepts 'permanent establishment' and 'foreign business establishment'.
Van Schaik, Rozelle +1 more
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Jurnal Magister Hukum Udayana, 2014 Companies with a permanent establishment is a form of a business carried on in Indonesia, carried out either by an individual or entity whose establishment was not done in Indonesia. The company with a permanent establishment differences with the concept
Putu Ratih Prabandari
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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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