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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DEVELOPMENT OF PERMANENT ESTABLISHMENT CONCEPT IN RUSSIA [PDF]
Вестник университета, 2017 The article describes the specifics of the taxation of organizations in the digital economy as well as emergence, development and application of the concept of permanent establishment in Russia and abroad.
S. Kravchuk
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Permanent Establishment in the Form of Dependent Agent in the Light of the Base Erosion and Profit Shifting Project [PDF]
Societas et Iurisprudentia, 2021 The subject of the paper is an analysis of the issue of permanent establishment in the form of a dependent agent. The main purpose is to list the positive conditions leading to the setting up of a permanent establishment in the form of a dependent agent.
Agata Lipińska
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Правоприменение, 2021 The subject. The author examines the criteria of creation of service permanent establishment (PE) in Russia and possibility of creation of this type of PE in providing R&D services in Russia by foreign specialists.The aim of the paper is to confirm ...
E. A. Zakharov
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NEW IN THE PRACTICE OF APPLYING INTERNATIONAL TAX RULES IN THE DIGITAL ECONOMY [PDF]
Северо-Кавказский юридический вестник, 2020 The article reveals the features of applying the new tax rules put forward in the digital economy, and the emergence of additional challenges to tax administrations.
Волова Лариса Ивановна
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PERMANENT ESTABLISHMENT. THE CRISIS OF THE ARTICLE 5 OECD MC IN THE DIGITAL ECONOMY [PDF]
Crónica Tributaria, 2021 The rise of the digital economy, breaking with business models that require a physical presence to develop their activities, has dislodged the traditional concept of permanent establishment set out in Article 5 OECD MC.
Montserrat Hermosín Álvarez
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Tax Economic Analysis of the European Commission's Digital Service Tax Proposal
International Journal of Public Finance, 2021 The European Commission proposes a new tax of 3% on union-level revenues to ensure that the member states of the European Union can get a fair share of the income of multinational digital companies.
Ali Çelikkaya
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New Tax Reality for Permanent Establishment of Foreign Enterprises in Poland in a Post-Beps Era [PDF]
, 2022 The main aim of this contribution is to make a review and assess the application of BEPS Action 7 recommendations by the tax administration in Poland when determining whether a non-resident enterprise operating in Poland should be considered to have a ...
Marcin Jamrozy +5 more
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Service permanent establishment in international tax law [PDF]
, 2022 Przedmiotem analizy dokonanej w artykule jest instytucja zakładu, występująca na gruncie międzynarodowego prawa podatkowego. Celem artykułu jest natomiast przedstawienie wersji zakładu usługowego, opracowanych przez OECD i ONZ, a także analiza relacji ...
Woźniak, Tomasz +2 more
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Base erosion and profit shifting by Google and platform market competition in Korea [PDF]
SHS Web of Conferences, 2020 The adoption of Google Taxes is often mentioned with respect to corporate taxes avoided for a MNE that does not have a permanent establishment in the domestic market.
Lee Taehee
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