The Resource Permanent establishments in the construction industry

Permanent establishments in the construction industry

Label
Permanent establishments in the construction industry
Title
Permanent establishments in the construction industry
Creator
Subject
Language
eng
Summary
In the case of Krupp Uhde GmbH, the Mumbai Tribunal has given a key decision on construction permanent establishments (PEs). Key learnings from the decision are as follows: 1. For calculating the threshold period, consolidation of unconnected projects needs to be done only in cases where the tax treaty specifically provides for it. 2. Date of commencement of existence of a PE would depend on whether the activity is undertaken on stand-alone basis or is dependent on any past activities relating to the project. 3. Intervening period caused on account of temporary and seasonal interruptions cannot be excluded. 4. Threshold period is to be counted activity-wise, irrespective of the years involved
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 37 (2009),
http://library.link/vocab/creatorName
  • Rawal, R
  • Bagri, N
Language note
English
http://library.link/vocab/subjectName
  • OECD Model
  • case law
  • PE
  • construction project
  • tax treaty
Label
Permanent establishments in the construction industry
Instantiates
Publication
Label
Permanent establishments in the construction industry
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...