Results 201 to 210 of about 66,714 (266)

Digital Permanent Establishment - 'Significant Digital Presence' as a Basis for Permanent Establishment Taxation

, 2018
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Establishing early permanence

Children and Young People Now, 2023
New practice standards aim to support social care organisations to develop early permanence
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The taxation of permanent establishments

Asia-Pacific Tax Bulletin, 2009
A practical insight on the taxation of permanent establishments under the new corporate income tax law.
N. Nguyen, C. Llanes Navarro
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Agency Permanent Establishments

International Transfer Pricing Journal, 2010
Part 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
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The Permanent Establishment: Still a (Permanent) Requirement?

EC Tax Review, 2014
This 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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The Subsidiary as a Permanent Establishment

Bulletin for International Taxation, 2010
In this article, the authors summarize the discussion on the topic of the subsidiary as a permanent establishment, which was considered by Seminar A of the 64th Congress of the International Fiscal Association, held in Rome, Italy on 30 August 2010.
Günther, Oliver-Christoph, Schoueri, Luís Eduardo   +1 more
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The Concept of Permanent Establishments

European Taxation, 2014
The 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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Business Restructuring and Permanent Establishments

International Transfer Pricing Journal, 2010
This 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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Commissionaire Agency Permanent Establishments

International Transfer Pricing Journal, 2010
Part 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
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How “Permanent” Should a “Material Permanent Establishment” Be?

European Taxation, 2009
In 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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