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

Resource Information

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

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

Creator

• Ma, G-M

Subject

• PE
• UN Model
• services PE

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

Geographic coverage

International

Language note

English