The Resource Principles of determining income of foreign permanent establishments

Principles of determining income of foreign permanent establishments

Label
Principles of determining income of foreign permanent establishments
Title
Principles of determining income of foreign permanent establishments
Creator
Subject
Summary
Discussion of a decision of the Federal Tax Court of 30 August 1995 which examined the principles under which a permanent establishment tax planning model would work. The issue in this case was whether the interest and royalties were exempt from taxation in Germany under Art. 24(1) no. 1 of the treaty by reason of being effectively connected with the trading activity of the permanent establishment that the taxpayer had in Switzerland through its participation in the partnership
Citation source
In: European taxation. - Amsterdam. - Vol. 36 (1996), no. 7 ; p. 249-250
http://library.link/vocab/creatorName
Kraft, G
Language note
English
http://library.link/vocab/subjectName
  • PE
  • case law
  • effectively connected income
  • tax treaty
Label
Principles of determining income of foreign permanent establishments
Instantiates
Publication
Label
Principles of determining income of foreign permanent establishments
Publication

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