Results 211 to 220 of about 65,725 (266)
Some of the next articles are maybe not open access.
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
Commissionaire 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
B. Santiago, J. Almeida Fernandes
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
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
Italy: is there a permanent establishment?
2016The author in this chapter of the book analyzes the Supreme Court decision No. 5649 delivered on 20 March 2015 which deals with the existence of a permanent establishment (PE) (stabile organizzazione occulta) in Italy of a non-resident company.
openaire +1 more source