The Resource Permanent establishment, "building sites" and "observations" on the commentary : some comments in light of the recent Supreme Court decision in Case No. 28059

Permanent establishment, "building sites" and "observations" on the commentary : some comments in light of the recent Supreme Court decision in Case No. 28059

Label
Permanent establishment, "building sites" and "observations" on the commentary : some comments in light of the recent Supreme Court decision in Case No. 28059
Title
Permanent establishment, "building sites" and "observations" on the commentary : some comments in light of the recent Supreme Court decision in Case No. 28059
Creator
Subject
Language
eng
Summary
The relationship between the general PE definition in article 5(1) of the OECD Model (2017) and the examples set out in the "positive list" in article 5(2) has been a longstanding issue. This topic was the subject of an "observation", the legal effect and scope of which are uncertain. The recent decision of the Italian Supreme Court in Case No. 28059 (24 November 2017) has shed some light on these matters and is the focus of this note
Citation source
In: European taxation. - Amsterdam. - Vol. 59 (2019), no. 2/3 ; p. 132-134
http://library.link/vocab/creatorName
Guarino, S
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • OECD Model
  • case law
  • PE
  • construction project
Label
Permanent establishment, "building sites" and "observations" on the commentary : some comments in light of the recent Supreme Court decision in Case No. 28059
Instantiates
Publication
Label
Permanent establishment, "building sites" and "observations" on the commentary : some comments in light of the recent Supreme Court decision in Case No. 28059
Publication

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