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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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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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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Attribution of profits to permanent establishments under UK law – Inbound situations – (UK permanent establishment of a non-resident company) [PDF]
This disseration examines past uncertainties and current practice determining the legal position in the United Kingdom on taxing the profits of non-UK resident companies trading through Permanent Establishments (PEs).
Kepper, Philipp
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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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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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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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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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