Host country taxation of host country sales subsidiary

Resource Information

The work Host country taxation of host country sales subsidiary represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Host country taxation of host country sales subsidiary

Creator

• Liebman, H.M.

Subject

• subsidiary company

Summary

Facts: Selco, a corporation in foreign country F, is engaged in a business of manufacturing consumer products. Selco has been selling its products directly to retailers in host country H and surrounding jurisdictions, but has now determined that it would be advantageous to penetrate the various markets in a more organized fashion. Accordingly, Selco proposes to lease an office in host country H and assign salesmen to promote the sale of Selco products in H and surrounding jurisdictions. It is contemplated that the salesmen assigned to the sales office in country H will act solely as Selco's agents for the sale of Selco products, and Selco will discontinue its sales activities with respect to the retailers in H and surrounding jurisdictions. Question: What are the country H tax consequences associated with organizing the sales office as a country H corporate subsidiary (Subco) of Selco?

Citation source

In: Tax Management international forum. - London. - Vol. 1 (1980),

Language note

English