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Permanent Establishment

38 published works

  1. International Financial Law Prof Blog

    Google, France Tax Raid, and Texas Hold’em

    By William Byrnes

    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…

  2. 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…

  3. Corporate & Financial Weekly Digest

    OECD Proposes Changes to the Definition of Permanent Establishment

    By David A. Brennand

    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…

  4. 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…

  5. La Revue

    Transfert d’établissement stable au sein de l’UE

    By Squire Patton Boggs

    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…

  6. 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…

  7. 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…

  8. 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,…