The Resource Subcontracting services to a company and a permanent establishment according to article 5 paragraph 3 letter b) UN Model Convention

Subcontracting services to a company and a permanent establishment according to article 5 paragraph 3 letter b) UN Model Convention

Label
Subcontracting services to a company and a permanent establishment according to article 5 paragraph 3 letter b) UN Model Convention
Title
Subcontracting services to a company and a permanent establishment according to article 5 paragraph 3 letter b) UN Model Convention
Creator
Subject
Language
eng
Summary
This articles examines the question whether subcontracting another company can amount to a permanent establishment (PE) according to Article 5 paragraph 3 letter b) of the United Nations Model Convention. In doing this, it looks at alternative service PE clauses, decisions and regulations in various jurisdictions and the interrelationship with the PE profit allocation clause and the non-discrimination clause. It argues that a PE through subcontracting another company would lead to dissatisfactory results
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 45 (2017), no. 6/7 ; p. 461-466
http://library.link/vocab/creatorName
Ma, G-M
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • PE
  • services PE
  • UN Model
Label
Subcontracting services to a company and a permanent establishment according to article 5 paragraph 3 letter b) UN Model Convention
Instantiates
Publication
Label
Subcontracting services to a company and a permanent establishment according to article 5 paragraph 3 letter b) UN Model Convention
Publication

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