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" permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment... "
Tax Conventions with Belgium, Finland, Trinidad and Tobago, and the ... - Page 81
by United States. Congress. Senate. Committee on Foreign Relations - 1971 - 177 pages
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Congressional Serial Set

1992
...(Interest), and Article 12 (Royalties). ARTICLE 5 Permanent Establishment 1. For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment"...
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Explanation of Proposed Income Tax Treaty (and Proposed Protocol) Between ...

U S Dept of Health & Human Services, Usgpo - 1993 - 60 pages
...under Article 6 (Business Profits). In general, under the proposed treaty, a permanent establishment is a fixed place of business through which a resident of one of the treaty countries engages in business in the other treaty country. For this purpose no distinction is...
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Multilateral Tax Treaties

Helmut Loukota, Albert J. Rädler, Josef Schuch, Franz Wassermeyer, Gerald Toifl, Christoph Urtz - 1998 - 250 pages
...of effective management is situated. Article 5 PERMANENT ESTABLISHMENT 1 . For the purposes of this Convention, the term ,,permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term ,,permanent establishment"...
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The Impact of Community Law on Tax Treaties:Issues and Solutions

Pasquale Pistone - 2002 - 405 pages
...Permanent establishment Article 5 Multilateral Tax Treaty Permanent establishment For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment"...
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Treaties and International Agreements Registered Or Filed and Recorded with ...

United Nations Staff - 2002 - 556 pages
...Agreement to such person. Article 5 Permanent Establishment 1 . For the purposes of this Agreement, the term "permanent" establishment" means a fixed place of business through which the business of an enterprise of a Contracting State is wholly or partly carried on. 162 2. The term...
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Dispute Settlement Reports 2002: Volume 1, Pages 1-585

World Trade Organization - 2004 - 590 pages
...Convention is defined in its Article 5;126 Article 5 PERMANENT ESTABLISHMENT 1 . For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. 2. The term "permanent establishment"...
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Multilingual Texts and Interpretation of Tax Treaties and EC Tax Law

Guglielmo Maisto - 2005 - 344 pages
...consideration. 28 Article 5 contains the definition of a PE and reads as follows: (1) For the purpose of this Convention the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on[...]. (3) A building site or construction...
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Tax Planning for Expatriates in China

Deloitte Touche Tohmatsu (Firm) - 2005 - 412 pages
...latter state, and only to the extent that the profits are attributable to the permanent establishment. The term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. Generally speaking, it includes: •...
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International Taxation: U.S. Taxation of Foreign Persons and ..., Volume 3

Joseph Isenbergh - 2006
...of a "permanent establishment" in the US Model Treaty is in Article 5(1): For the purposes of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried onJ9 The term "fixed place of business" in...
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The Taxation of Permanent Establishments: An International Perspective

Radhakishan Rawal - 2006 - 551 pages
...is wider as compared to Article 5(1) of the DTAA, which reads as follows: "For the purpose of this Convention, the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on". The definition under section 92F(iiia)...
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