Permanent establishment in international taxation

Resource Information

The work Permanent establishment in international taxation 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, Books.

Label

Permanent establishment in international taxation

Contributor

• Mehta, A. (Amar)

Subject

• OECD Model
• PE
• UN Model
• advance ruling
• agency PE
• services PE
• tax treaty

Language

eng

Summary

This book gives a comprehensive commentary on law relating to permanent establishment (PE) as defined in Art. 5 of the OECD 2010 Model Convention, the UN 2011 Model Convention and various bilateral tax treaties. An in-depth analysis of almost all leading court decisions, advance rulings and administrative rulings in various countries including India, the United States, Germany, the Netherlands, Belgium, Norway, Switzerland, Spain, Canada, New Zealand, South Africa, Russia, Luxembourg, Italy, Austria and Greece. The book thoroughly discusses practical implications of various types of PE, including: fixed place PE [Art. 5(1) of model conventions and various bilateral tax treaties]; PE illustrations [Art. 5(2)]; construction PE [Art. 5(3)] [Art. 5(2) in certain bilateral tax treaties]; service PE [Art. 5(3)] [Art. 5(2) in certain bilateral tax treaties]; PE - Exclusion Provisions [Art. 5(4)]; dependent agency PE [Art. 5(5)] and independent agents [Art. 5(6)]; and PE implications in case of subsidiary/group entities [Art. 5(7) of the OECD 2010 Model Convention, Art. 5(8) of the UN 2011 Model Convention and various bilateral tax treaties]. Law stated in this book is on May 2012

Geographic coverage

International

Index

no index present

Language note

English

Literary form

non fiction