The Resource Permanent establishment : no deduction of losses of foreign permanent establishment

Permanent establishment : no deduction of losses of foreign permanent establishment

Label
Permanent establishment : no deduction of losses of foreign permanent establishment
Title
Permanent establishment : no deduction of losses of foreign permanent establishment
Subject
Summary
The Supreme Administrative Court considered a case involving a French company that carried on business activities through a PE in Algeria and that, in order to recoup losses incurred in Algeria, claimed various deductions in connection with the losses in computing its taxable income for French corporate income tax purposes
Citation source
In: European taxation. - Amsterdam. - Vol. 25 (1985),
Language note
English
http://library.link/vocab/subjectName
  • case law
  • tax treaty
  • PE
  • formulary apportionment
Label
Permanent establishment : no deduction of losses of foreign permanent establishment
Instantiates
Publication
Label
Permanent establishment : no deduction of losses of foreign permanent establishment
Publication

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