Results 211 to 220 of about 65,628 (266)
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The Concept of Permanent Establishments
European Taxation, 2014The 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, 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
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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”.
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Permanent Establishments in the Construction Industry
Intertax, 2009In the case of Krupp Uhde GmbH, the Mumbai Tribunal has given a key decision on Construction Permanent Establishment (PE). Key learnings from the decision are as follows: – For calculating the threshold period, consolidation of unconnected projects needs to be done only in cases where the Tax Treaty specifically provides for it.
Radhakishan Rawal, Neha Bagri
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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 ...
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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.
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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.
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