Topic
Permanent Establishment
38 published works
International Financial Law Prof Blog
Google, France Tax Raid, and Texas Hold’em
Reuters reported yesterday that in highly dramatic fashion the French tax authorities and IT specialists raided Google's headquarters. I don't own Google stock. I don't live in California anymore where…
Technology's Legal Edge
DIVERTED PROFITS TAX – FIRST THOUGHTS
By Mike Conradi
By Paul Rutherford, partner, London The UK Government intends to introduce a 25% "diverted profits tax" (DPT) from 1 April 2015. The tax is designed to catch the artificial erosion…
Corporate & Financial Weekly Digest
OECD Proposes Changes to the Definition of Permanent Establishment
As previously reported (here), the Organisation of Economic Co-operation and Development (OECD) published a 15-point Base Erosion and Profit Shifting (BEPS) Action Plan that provided a set of recommendations for…
China Law Insight
China Tax: Unveiling the International Secondment Arrangement
By King & Wood
ByTony Dong, Daisy Duan and Jiang Junlu King & Wood Mallesons Corporate Group Over the years, it has been a common practice that multinational companies (“Home Entity”) dispatch expatriate employees (“Secondees”) to the…
La Revue
Transfert d’établissement stable au sein de l’UE
Un arrêt de la CJCE du 6 septembre 2012 (Commission Européenne c/ République portugaise, affaire 38/10, 4e ch.) a rappelé que le principe de liberté d’établissement posé à l’article 49…
European Union and Italian International Tax Law Blog
Italian Supreme Court Reverses Course on Permanent Establishment Issue
By Marco Rossi
Italian Supreme courts reverses course on the issue of re-characterization of an Italian foreign owned company as permanent establishment of its foreign parent. The decisions seems to depart significantly from…
China Law Blog
China Company Taxes: Don’t Let the Tail Wag the Dog.
By Dan Harris
Excellent post on the China Tax Insight Blog, based largely on a couple of comments on our blog. The post is A Seeming Solution to the China PE problem [link…
European Union and Italian International Tax Law Blog
Madeira Company Held Liable to Tax in Italy, Regional Tax Court Ruled
By Marco Rossi
Italian Regional Tax Court found a Madeira company engaged in the business of purchasing and selling goods had its permanent establishment in Italy and was subject to tax in Italy,…