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Topic

Permanent Establishment

38 published works

  1. 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…

  2. 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…

  3. 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…

  4. 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…

  5. 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…

  6. 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…

  7. International Financial Law Prof Blog

    French Court Finds Google Does Not Have a French Permanent Establishment. Spares $1.2 Billion Tax Bill.

    By William Byrnes

    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…

  8. International Financial Law Prof Blog

    OECD releases BEPS discussion drafts on attribution of profits to permanent establishments

    By William Byrnes

    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…

  9. 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…

  10. International Financial Law Prof Blog

    OECD Release of BEPS discussion draft on attribution of profits to permanent establishments

    By William Byrnes

    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…