Topic
Permanent Establishment
38 published works
India Tax Law
Subsidiary is Not a Permanent Establishment but Beware the ‘Virtual Projection’ Risk
By CAM Tax Team
The Income Tax Appellate Tribunal, Delhi (ITAT) recently delivered a very significant decision in the case of Nokia Networks O.Y (Assessee)[1] on the issue of its permanent establishment (PE) in…
European Union and Italian International Tax Law Blog
Italy Enacted The Economic Nexus Rule And Other Changes To The Definition of Permanent Establishment
By Marco Rossi
With the Budget Law for 2018 (Law n. 205 of December 27, 2017), Italy amended the definition of the term "permanent establishment" set forth in article 162 of the Italian…
Global Media and Communications Watch
Italy: New Web Tax and definition of permanent establishment
By Fulvia Astolfi, Serena Pietrosanti, Maria Cristina Conte
The Web Tax Italy has introduced a new so-called "Web Tax", a new tax on certain digital transactions. This will apply from 1 January following the issue of the relevant…
India Tax Law
Outsourcing of Back Office Support Functions Does Not Create a Permanent Establishment
By S.R. Patnaik
Multinational enterprises often outsource back-office support operations to their captive subsidiaries in India. Additionally, foreign parent companies second their employees to provide guidance to the Indian subsidiary in the provision…
La Revue
Notion d’établissement stable dans le cadre d’un contrat d’agent
By Stephanie Negre, Squire Patton Boggs
TA Paris, 12 octobre 2017 n°1505178, 1505165, 1505113, 1505147 et 1505126 Cinq décisions rendues par le Tribunal administratif de Paris viennent préciser la notion d’établissement stable dans le cadre d’un…
India Tax Law
Service PE Does Not Require Physical Presence of Employees
By S.R. Patnaik
Permanent Establishment (PE) is a significant feature of bilateral tax treaties and is a key threshold adopted by source countries to tax profits earned by non-resident entities from the business…
International Financial Law Prof Blog
French Court Finds Google Does Not Have a French Permanent Establishment. Spares $1.2 Billion Tax Bill.
La société irlandaise Google Ireland Limited (GIL), filiale du groupe américain Google Inc., commercialise, en France notamment, un service payant d’insertion d’annonces publicitaires en ligne, « AdWords », corrélé au moteur de…
International Financial Law Prof Blog
OECD releases BEPS discussion drafts on attribution of profits to permanent establishments
Public comments are invited on the following discussion drafts: Attribution of Profits to Permanent Establishments, which deals with work in relation to Action 7 ("Preventing the Artificial Avoidance of Permanent…
India Tax Law
Formula One: SC Lays Down the Formula for Permanent Establishment
By S.R. Patnaik
With globalisation spreading economic activities across jurisdictions, enterprises nowadays have a presence in several jurisdictions. The taxability of activities undertaken by companies on foreign soil is closely linked to whether…
International Financial Law Prof Blog
OECD Release of BEPS discussion draft on attribution of profits to permanent establishments
Discussion Draft on the Attribution of Profits to Permanent Establishments The Final Report on Action 7 of the BEPS Action Plan ("Preventing the Artificial Avoidance of Permanent Establishment Status") mandates…