Topic
Permanent Establishment
38 published works
European Union and Italian International Tax Law Blog
Italian Tax Agency Rules on Italy’s Foreign Branch Exemption
By Marco Rossi
With tax ruling n. 18/2022 of January 12, 2022 (Risposta_18_12.01.2022), the Italian tax agency ruled that for the foreign branch tax exemption to apply, a permanent establishment must exist in…
Best Methods
Landmark Decision in France Regarding PE of Digital Company
In a decision dated December 11, 2020 (Value Click Case), the French Administrative Supreme Court overturned a Paris Court of Appeal decision dated March 1, 2018, and concluded that the…
Best Methods
Singapore Issues New Guidance on Tax Residency & Permanent Establishments
By Pieter de Ridder, Anthony D. Pastore
As discussed in a recent blog post, the Inland Revenue Authority of Singapore (“IRAS”) has been issuing guidance on the impact of COVID-19 on transfer pricing issues. This week, IRAS…
Labor & Employment Law Blog
Employment, Tax, and Visa Issues Associated With the Overseas Telecommuter
By Kristi Thomas, Frank Dworak, Greg Berk
Given the pandemic and all that has come along with it, telecommuting has become the new norm. Employers are increasingly faced with difficult legal issues pertaining to not only the…
COVID-19 Response Blog
COVID-19 Travel Restrictions: US Tax Relief and Cross-Border Tax Considerations
By Megan K. Hall, Jonathan A. Sambur, Michael Lebovitz, Xiao Xiao
Background COVID-19 has left employee workforces separated from their country of assignment. To continue operations, employers transitioned employees to work-from-home or other virtual work arrangements. Globally, tax authorities are considering…
India Tax Law
OECD’s views on factors impacting tax policies and determination of ‘PE’ and ‘POEM’ in times of COVID-19
By Surajkumar Shetty, CAM Tax Team
In our previous blog, we discussed some measures which were suggested by the Organisation for Economic Co-operation and Development (“OECD”) to ease the cash flow crunch being faced by taxpayers…
European Union and Italian International Tax Law Blog
Italian Tax Agency, Taxpayer Settled The Biggest “Silent” Permanent Establishment Tax Case For a Record Amount of 1.250 Billion Euro In Taxes And Penalties
By Marco Rossi
The Italian financial newspaper "Il Sole 24 Ore" reported today that Koering, the French-owned conglomerate which controls some of the most renowned and revered luxury brands in the world, such…
International Financial Law Prof Blog
Proposed India profit attribution rules reject OECD approach, add “sales” and “users” as apportionment factors
India’s Central Board of Direct Taxes (CBDT) on April 18 asked for public feedback on proposed new rules for attributing profits to Indian permanent establishments (PEs) that differ from the…
Tax Controversy 360
IRS Releases Practice Units on Permanent Establishments
By K. Christy Vouri-Misso, Kevin Spencer
On January 29 and 30, 2019, the Internal Revenue Service’s Large Business and International (LB&I) division released new Practice Units on Permanent Establishments, which can be found here and here.…
La Revue
Affaire Bevola : l’utilisation des pertes d’un établissement stable européen précisées
CJUE 12 juin 2018, aff.C-650/16, A/S Bevola Il s’agissait ici d’une société danoise dont la succursale en Finlande avait fermé. La société danoise avait demandé la déduction des pertes de…