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Artículos de revistas sobre el tema "Permanent establishment"

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Autor: Grafiati

Publicado: 4 de junio de 2021

Última modificación: 25 de abril de 2022

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1

de L’Hotellerie-Fallois, Domingo J. Jiménez-Valladolid. "The Permanent Establishment: Still a (Permanent) Requirement?" EC Tax Review 23, Issue 1 (1 de febrero de 2014): 4–15. http://dx.doi.org/10.54648/ecta2014002.

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This article examines the relevance of the 'remaining permanent establishment' requirement under the Merger Directive in the light of the recent jurisprudence of the Court of Justice of the European Union on corporate exit taxes. This requirement is a mechanism meant to ensure that Member States will be able to effectively exercise their taxing rights. However, the decisions of the Court of Justice in this field may have an impact on how the common tax system envisaged in the Merger Directive functions, obliging Member States to extend deferral to situations where the requirements envisaged in the Directive are not fulfilled.

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2

이준규 y Sangdo Lee. "Passive Partner and Permanent Establishment". Journal of IFA, Korea 26, n.º 1 (febrero de 2010): 145–66. http://dx.doi.org/10.17324/ifakjl.26.1.201002.002.

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3

Shalhav, Sarig. "The Revised Permanent Establishment Rules". Intertax 31, Issue 4 (1 de abril de 2003): 131–47. http://dx.doi.org/10.54648/taxi2003031.

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4

Geurts, Matthias. "Server as a Permanent Establishment?" Intertax 28, Issue 4 (1 de abril de 2000): 173–75. http://dx.doi.org/10.54648/262455.

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5

Pleijsier, Arthur. "The Agency Permanent Establishment Under Revision?" Intertax 25, Issue 6/7 (1 de junio de 1997): 247–54. http://dx.doi.org/10.54648/taxi1997044.

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6

Van Schalkwyk, Linda y Rozelle Van Schaik. "A critical analysis of the concepts ‘Permanent Establishment’ and ‘Foreign Business Establishment’". Journal of Economic and Financial Sciences 5, n.º 1 (30 de abril de 2012): 63–82. http://dx.doi.org/10.4102/jef.v5i1.306.

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The objective of this study was to analyse and compare the concepts permanent establishment and foreign business establishment in order to make recommendations regarding the required additions and amendments to replace the concept foreign business establishment with the internationally recognised and accepted concept permanent establishment. The proposed replacement of the concept foreign business establishment with an internationally recognised and accepted tax concept will enhance the international compatibility of the Income Tax Act 58 of 1962. The use of an internationally recognised and accepted tax concept will provide clarity and certainty regarding the tax implications of section 9D(9)(b) for those affected by it. After comparing the two definitions it was found that, subject to certain suggested additions and amendments, the internationally recognised and accepted concept permanent establishment can replace the concept foreign business establishment in section 9D(9)(b) of the Income Tax Act 58 of 1962 without having a material impact on the objective of section 9D(9)(b). This replacement is possible due to the mutual objective of and the similar components contained in the definitions of the concepts permanent establishment and foreign business establishment.

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7

Colabella, Rachel. "The Phenomenon of Double Taxation and the Interpretation of Article V (Permanent Establishments) of the Canada-U.S. Income Tax Convention (1980)". Alberta Law Review 33, n.º 3 (1 de junio de 1995): 626. http://dx.doi.org/10.29173/alr1133.

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Double taxation is a phenomenon that arises when two or more states have the jurisdiction to tax the common income of the same person, whether a company or an individual. The author considers the causes and effects of double taxation and then examines bilateral double taxation treaties as an important method of reducing this problem. Double taxation is of growing concern due to the ever-increasing international aspects of doing business, which affect both companies and individuals. Ultimately, double taxation impedes the movement of capital, technology, persons and services between states, thus hindering lasting economic co operation. The history of double taxation treaties, some model treaties and finally the 1980 Canada-U.S. Convention are discussed. The writer closely examines the Permanent Establishment provision in the Convention. The concept of a Permanent Establishment is central to the Canada-U.S. Convention, as it is the mechanism by which a resident of one state can be taxed by the other state. The business profits of a resident can only be taxed by the other state if that resident carried on business through a Permanent Establishment in the other state. Drawing on Canadian, U.S. and international taxation treaty interpretations, the author outlines the comprehensive test for determining the existence of a Permanent Establishment. Building on this analysis, she discusses the practical tax planning problem of whether to conduct business in foreign States through Permanent Establishments or through some other entities. Finally, the writer discusses both the advantages and disadvantages of the current Permanent Establishment provision and its effect on trade between Canada and the U.S.

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8

Moreno, Andrés Báez. "COVID-19 and Fiscal Policies: Unnecessary and Yet Harmful: Some Critical Remarks to the OECD Note on the Impact of the COVID-19 Crisis on Tax Treaties." Intertax 48, Issue 8/9 (1 de agosto de 2020): 814–30. http://dx.doi.org/10.54648/taxi2020080.

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The COVID-19 pandemic has restricted freedom of movement and imposed forced, or at least unplanned, displacement. Insofar as the International Tax Regime continues to be based on the physical presence of individuals, this has led to unexpected and often undesirable tax consequences. The reaction of the OECD Secretariat to this situation has been to issue a note claiming, in essence, that everything remains the same. This article critically approaches that note by exposing its general methodological flaws and analysing each of the four specific aspects to which it refers: Permanent Establishments (PEs), Place of Effective Management (POEM), Cross-Border Workers and Residence of Individuals. Double taxation conventions, COVID-19, residence, permanent establishment, agents, services-permanent establishment, place of effective management, cross-border workers, tie-breaker rules.

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9

Kravchuk, S. V. "DEVELOPMENT OF PERMANENT ESTABLISHMENT CONCEPT IN RUSSIA". Vestnik Universiteta, n.º 11 (2017): 100–104. http://dx.doi.org/10.26425/1816-4277-2017-11-100-104.

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10

Quilitzsch, Carsten y Xaver Ditz. "The Definition of Permanent Establishment: Current OECD and German Case Law Developments". Intertax 40, Issue 10 (1 de octubre de 2012): 556–65. http://dx.doi.org/10.54648/taxi2012055.

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Article 5 of the OECD MTC settles the definition of the treaty concept of permanent establishments. Although in the past Article 5 has remained untouched, the commentary on the OECD MTC has several times been adjusted on the changing forms of international business, constantly lowering the bar for what constitutes a permanent establishment. Furthermore recent rulings of Germany's Federal Finance Court illustrate, that the court also seems to sympathize with an increasingly broader understanding. Since the practical application of Article 5 raises a number of questions, the OECD has released a public discussion draft listing proposals for changes to the 2014 update of the commentary on Article 5. The authors give an overview of the proposed changes as well as on recent rulings of the German Federal Finance Court addressing the requirements needed to constitute a permanent establishment.

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11

Rocha, Sergio André. "Agency Permanent Establishment Brazilian Style: Taxation of Profits Earned Through Commission Merchants, Agents and Representatives". Intertax 41, Issue 8/9 (1 de agosto de 2013): 444–49. http://dx.doi.org/10.54648/taxi2013040.

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This article explores the treatment of agency permanent establishments in Brazilian tax regulations. Brazil's legislation does not have general permanent establishment rules. However, it deals with certain types of agency PEs. After analyzing domestic regulations we have also explored the limited case law there is in Brazil about this topic. The last section of the article is dedicated to the interaction between Brazil's domestic rules and the double tax conventions signed by the country.

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12

Laurinaitis, Marius, Darius Stitilis, Irmantas Rotomskis, Otabeg Azizov y Nataliia Marchuk. "Limitations of the concept of permanent establishment and e-commerce". Independent Journal of Management & Production 11, n.º 9 (1 de noviembre de 2020): 2308. http://dx.doi.org/10.14807/ijmp.v11i9.1429.

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The concept of permanent establishment introduced over a century ago became obsolete in the XXI age. It is completely irrelevant in terms of modern online business. Recent OECD initiatives are only a late reaction to the internationally observed legal loophole in taxing profits of e-commerce companies. Steps taken by the international community over the last few years reveal considerable diversity in approaches towards the concept of permanent establishment. Even the key principles to be followed in the development of the new concept of permanent establishment have not been agreed so far. The present article is an attempt to propose the major principles to be followed in updated interpretations of the concept of permanent establishment equally effective in terms of both big multinationals and SMEs.

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13

윤현석. "Tax problems to permanent establishment on tax treaty". Journal of IFA, Korea 23, n.º 2 (agosto de 2007): 1–33. http://dx.doi.org/10.17324/ifakjl.23.2.200708.001.

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14

Pleijsier, Arthur. "The Agency Permanent Establishment, Practical Applications. Part Two." Intertax 29, Issue 6/7 (1 de junio de 2001): 218–32. http://dx.doi.org/10.54648/335461.

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15

Zakharov, E. A. "Creation of service permanent establishment in Russian Federation when providing R&D services by foreign specialists". Law Enforcement Review 5, n.º 2 (5 de julio de 2021): 120–31. http://dx.doi.org/10.52468/2542-1514.2021.5(2).120-131.

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The subject. The author examines the criteria of creation of service permanent establishment (PE) in Russia and possibility of creation of this type of PE in providing R&D services in Russia by foreign specialists.The aim of the paper is to confirm or refute the hypothesis that the provision of R&D ser-vices by foreign specialists in Russia creates a service permanent establishment. The author also analyzes the current science legislation of Russia and suggests ways of its improvement to reduce tax risks.The methodology. The author used general scientific dialectical method of scientific knowledge, the formal-logical method, in particular analysis and synthesis in examining criteria of creation of service permanent establishment. The author also uses a systematic method and a simulation method to establish the relationship between the science legislation and tax legislation.The main results. The activity of foreign scientific specialists in Russia potentially originates the risk of creation of a permanent establishment on the territory of the Russia for the foreign organization, which sent that specialist to provide the relevant services. However, when comparing the international and domestic law enforcement approach, the author revealed a feature of the latter, which consists in applying the criteria of the physical type of permanent establishment to a service permanent establishment, which in turn gives rise to legal uncertainty and the risk of double taxation in some situations. There is no relevant judicial practice on the topic. Budgetary scientific organizations have a certain priority over commercial scientific organizations when involving foreign specialists in R&D activities in Russia.Conclusions. The criteria for the creation of service permanent establishment (including the provision of R&D services) in domestic practice have an ambiguous, evaluative interpretation. However, the risks of discretion in assessing the criteria for creation of service permanent establishment can be eliminated by clarifying these criteria in the Tax Code of the Russian Federation. Amendments to the science legislation can also eliminate above and fore-going risks.

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16

Hermosín Álvarez, Montserrat. "PERMANENT ESTABLISHMENT. THE CRISIS OF THE ARTICLE 5 OECD MC IN THE DIGITAL ECONOMY". Revista Crónica Tributaria 180, n.º 3 (septiembre de 2021): 97–131. http://dx.doi.org/10.47092/ct.21.3.4.

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The rise of the digital economy, breaking with business models that require a physical presence to develop their activities, has dislodged the traditional concept of permanent establishment set out in Article 5 OECD MC. In the light of the precept’s loopholes, large multinationals have engaged in abusive practices to relocate their profits, thus avoiding contributing in the States where the income is generated in accordance with their economic capacity. In this paper, we examine the concept of permanent establishment included in art. 5 OECD MC, its typology following the BEPS Project’s modifications and the different scenarios that do not constitute a permanent establishment. We also explore whether its legal regime continues to be useful in today’s context or whether, on the contrary, the moment has come to abandon the concept of permanent establishment entirely due to the problems generated by today’s article 5 OECD MC, unable to respond to the challenges posed by the digital economy.

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17

Bagri, Neha y Radhakishan Rawal. "Permanent Establishments in the Construction Industry". Intertax 37, Issue 12 (1 de diciembre de 2009): 698–700. http://dx.doi.org/10.54648/taxi2009071.

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In the case of Krupp Uhde GmbH, the Mumbai Tribunal has given a key decision on Construction Permanent Establishment (PE). Key learnings from the decision are as follows: – For calculating the threshold period, consolidation of unconnected projects needs to be done only in cases where the Tax Treaty specifically provides for it. – Date of commencement of existence of PE would depend on whether the activity is undertaken on stand-alone basis or is dependent on any past activities relating to the project. – Intervening period caused on account of temporary and seasonal interruptions cannot be excluded. – Threshold period is to be counted activity-wise, irrespective of the years involved.

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18

Jungrog Suh. "A study on taxation of foreign corporation's Permanent Establishment". Management & Information Systems Review 29, n.º 3 (septiembre de 2010): 71–96. http://dx.doi.org/10.29214/damis.2010.29.3.004.

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19

Cibuľa, Tomáš y Matej Kačaljak. "Tax treaty override in Slovakia - Digital platform permanent establishment". Bratislava Law Review 2, n.º 1 (30 de junio de 2018): 80–88. http://dx.doi.org/10.46282/blr.2018.2.1.95.

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The article analyses the new “digital platform permanent establishment” concept as a legal fiction establishing a fixed place even in situations where there is no actual fixed place. The authors conclude that in the Slovak legal environment this concept is not capable of (i) being applied through the interpretation of the tax treaty, or (ii) overriding the tax treaty. Its practical implications in a tax treaty situation must be analysed on a case-by-case basis. The ineffectiveness of the concept mainly stems from the fact that Slovak statutory rules are generally incapable of overriding tax treaties. It may still be applicable in a dualist legal environment, but international law treaty override implications would still remain valid.

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20

Schlueter, David y Benjamin Tracy. "Sowing Method Effects on Clover Establishment into Permanent Pasture". Agronomy Journal 104, n.º 5 (septiembre de 2012): 1217–22. http://dx.doi.org/10.2134/agronj2012.0035.

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21

Tracy, Benjamin F., David H. Schlueter y Joao Paulo Flores. "Conditions that favor clover establishment in permanent grass swards". Grassland Science 61, n.º 1 (4 de diciembre de 2014): 34–40. http://dx.doi.org/10.1111/grs.12075.

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22

Le Tonquèze, M., C. Jamin, M. Böhme, R. Le Corre, M. Dueymes y P. Youinou. "Establishment and characterization of permanent human endothelial cell clones". Lupus 5, n.º 2 (abril de 1996): 103–12. http://dx.doi.org/10.1177/096120339600500204.

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23

Eisenbeiss, Justus. "BEPS Action 7: Evaluation of the Agency Permanent Establishment". Intertax 44, Issue 6/7 (1 de junio de 2016): 481–502. http://dx.doi.org/10.54648/taxi2016039.

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The article is devoted to one of the most controversial items of the Base Erosion and Profit Shifting (BEPS)-Project – Action 7, particularly the agency Permanent Establishment (PE) of Articles 5(5) and 5(6). Marking the threshold for source-state taxing rights, the PE has been at the centre of an entrenched debate since the concept’s emergence in the nineteenth century. Thus, working on the agency PE the OECD soon found itself caught between a rock and a hard place. With strong national interest for a high threshold on the one side and the increasing need to rebalance taxing rights due to globalization and the emergence of modern business models on the other side. This conflict shaped the consolations process and final output of Action 7. Ultimately, the Final Report settled for much less than the initially pursued globally supported holistic approach. The need for a substantial reform, however, remains and becomes more pressing with the introduction of unilateral measures. Moreover, with the agency PE in the spotlight, attention will inevitably be directed to the attribution of profits, an issue neglected in the BEPS Project. The inadequacies of the current attribution rules are examined in the second part of this article and a proposal is put forward.

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24

Pleijsier, Arthur. "The Agency Permanent Establishment: Allocation of Profits – Part Three". Intertax 29, Issue 8/9 (1 de agosto de 2001): 275–83. http://dx.doi.org/10.54648/339668.

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25

Skaar, Arvid Aage. "Erosion of the Concept of Permanent Establishment: Electronic Commerce". Intertax 28, Issue 5 (1 de mayo de 2000): 188–94. http://dx.doi.org/10.54648/265805.

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26

Pleijsier, Arthur. "The Agency Permanent Establishment: The Current Definition – Part One". Intertax 29, Issue 5 (1 de mayo de 2001): 167–83. http://dx.doi.org/10.54648/333272.

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27

Giner, Luis-Alfonso Martínez. "Further Discrimination of Permanent Establishments: Tax Incentive to Maintain or Create Employment in Spain". Intertax 39, Issue 2 (1 de febrero de 2011): 91–97. http://dx.doi.org/10.54648/taxi2011008.

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The Spanish 2010 General State Budgets Act contained an important innovation consisting of the incorporation in the Spanish tax system of a new tax incentive to maintain or create employment. The fact that this tax incentive is not applicable to permanent establishments (PE) raises the question of whether it constitutes an infringement of the non-discrimination principle that limits the freedom of establishment. In general, the principle of nondiscrimination has had a significant impact on the Spanish tax system, mainly in relation to direct taxes and, in particular, on PE. The case we shall now analyse is an example of this type of discrimination, which is prohibited both under the non-discrimination of PE clause envisaged in double taxation treaties and pursuant to the Community freedom of establishment.

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28

Schaffner, Jean. "The Territorial Link as a Condition to Create a Permanent Establishment". Intertax 41, Issue 12 (1 de diciembre de 2013): 638–51. http://dx.doi.org/10.54648/taxi2013062.

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It is generally accepted that a physical permanent establishment is characterized by three components: (i) it has to be permanent (not temporary); (ii) it has to be fixed (geographic or territorial link to the ground); and (iii) it has to be at the disposal of the business undertaking which uses it to carry out its activities. The purpose of this study is to analyse whether these three criteria are equally important for the qualification of a permanent establishment and whether, in the context of economic evolution over the last few years, of case law in the various countries that has analysed double tax treaties and of technological improvements, these criteria, in particular the territorial link, are still appropriate.

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29

Jungrog Suh, 김재승 y Dongchoon Choi. "A study on taxation of foreign corporation's Deemed Permanent Establishment". Tax Accounting Research ll, n.º 31 (marzo de 2012): 27–52. http://dx.doi.org/10.35349/tar.2012..31.002.

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30

Nanda, Ved P. "The Establishment of a Permanent International Criminal Court: Challenges Ahead". Human Rights Quarterly 20, n.º 2 (1998): 413–28. http://dx.doi.org/10.1353/hrq.1998.0016.

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31

Hamdan, Mohammad Abdul-Jalil. "Overview Of Rules Governing Attribution Profits Generated From Permanent Establishment". Advances in Social Sciences Research Journal 6, n.º 9 (8 de octubre de 2019): 339–54. http://dx.doi.org/10.14738/assrj.69.7173.

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In regard to the attribution of profits; this article concluded that there are still some uncertainties on the categorization on the taxation of the cross border businesses. Therefore, the OECD MTC has tried to harmonize the problem by employing some factual and functional evaluation of the challenges in the internal dealings. However, some countries mostly in the European Union had different methods that help in dealing with these problems. The paper on the other hand has tried to evaluate the solution in both treaty and non-treaty cases so as to achieve an amicable solution towards the same. In addition, the problem of double taxation still derives varied opinions by different commentaries by the United Nations and the OECD. The approach that has being proposed by the OECD MTC recently does not cover all the required areas of the problem. The hypothetical evaluation by the organization still faces some notable drawbacks in its implementation. The measures that have been employed so far do not uphold certainty to the individual taxpayers and businesses. Hence, the reliance of the authorities and business in these cases on documentation has been excessive. The paper establishes that the most ideal systems that would solve the current tax challenges are the one that would logically look at the inconsistencies observed in taxation. Therefore, the chapter proposes international discussions and agreements by use of a common and comparative law as the best way to achieve the desired taxation objectives. Thus, in order to protect the sovereignty of the countries and to ensure and confirm tax neutrality and fairness between source and residence countries, we are urgently in need to modify the current system of international taxation standards in accordance with new e-commercial environment. Furthermore, in pursuant to the basic principles of international tax law and to find better and essential solutions to the e-commerce issues relating to attribution of profits.

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32

Xue, Shuai, Iris Lewandowski y Olena Kalinina. "Miscanthus establishment and management on permanent grassland in southwest Germany". Industrial Crops and Products 108 (diciembre de 2017): 572–82. http://dx.doi.org/10.1016/j.indcrop.2017.07.024.

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33

Becker, Helmut. "The determination of income of a permanent establishment or branch". Intertax 17, Issue 1 (1 de enero de 1989): 12–15. http://dx.doi.org/10.54648/taxi1989003.

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34

Gunadi, Gunadi. "The Profits Directly or Indirectly Attributed to a Permanent Establishment". Journal of Tax and Business 2, n.º 2 (22 de septiembre de 2021): 84–97. http://dx.doi.org/10.55336/jpb.v2i1.19.

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This paper discussed a real case arising from the audit of a namely permanent establishment (PE) CHE operated by a CHE Ltd an enterprise residing in The People Republic of China (China).Having regular business of construction in Indonesia, this PE mantains a place of managementin Jakarta from where her businesses are managed. In 2018 this PE has finished a one-year construction project which was obtained under subcontract with an Indonesian company,namely, PT RDP at the costs of Rp 4,5 Trilyun (T). PT RDP concluded the main contract fromanother Indonesian State Owned Enterprise at the cost of Rp 5T. As this PE has alreadymaintaining a local place of management in this country, CHE PE may be called a aset-type PE‘(Gunadi, 1992, Taxation of Inbound Investment in Indonesia, APTIRC)). Most of the construtionmaterials, i.e., at least 60% of the total project costs, were imported by PT RDP from CHE Ltd (the PE‘s Head Office). This was done by Indonesian resident ompany under the import fees of 5%, as this company may claim the import facilities in respect of taxations.

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35

Ferrer, Francisco Antonio Vaquer. "The Concept of Permanent Establishment at the Spanish Courts: Special Reference to the Roche and Dell Cases". Intertax 44, Issue 8/9 (1 de agosto de 2016): 673–83. http://dx.doi.org/10.54648/taxi2016056.

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An accurate definition of the concept of permanent establishment is crucial to the application of the distributive rules provided by the Double Taxation Treaty, particularly, on business profits. In Spain, the cases of Roche and Dell have been very much talked about since the decisions of the Courts brought about a construction of the figure of permanent establishment far from the prevailing orthodox approach to the Commentaries of the Organization for Economic Co-operation and Development Model Tax Convention. The purpose of this broad interpretation of the concept of permanent establishment seems, then, clear: to avoid, with varying degrees of success, that multinational companies carrying on sizable business activity in Spain fail to pay taxes by means of a fabricated business structure scheme. This article shall, therefore, analyse this concept in the light of the Court’s decisions in the above mentioned cases.

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36

Garbarino, Carlo. "Permanent Establishments and BEPS Action 7: Perspectives in Evolution". Intertax 47, Issue 4 (1 de abril de 2019): 365–81. http://dx.doi.org/10.54648/taxi2019036.

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This article suggests that the judicial reasoning adopted within judicial trends developed at national level has been used in shaping evolving perspectives about the concept of permanent establishment adopted in the OECD Model. The article strives to achieve fuller comprehension of the issues raised by the Commentary in 2017, addresses different perspectives which can be adopted about preparatory/auxiliary activities that might prove useful in understanding the anti-fragmentation rule now introduced in Article 5(4.1) of the OECD Model and then focuses on the concept of the agency permanent establishment ‘PE’ in light of the functional analysis developed by the OECD, with particular attention to the concrete use of the concept of ‘authority to conclude contracts’ within the functional approach now adopted by the OECD Model, particularly with regard to commissionaire strictures.

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37

Schwarz, Magdalena. "Can the Switch-Over Rule and the Role of Permanent Establishments be considered the Neglected Stepchildren of the GloBE Proposal?" Intertax 49, Issue 12 (1 de diciembre de 2021): 986–94. http://dx.doi.org/10.54648/taxi2021100.

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As has already been learned as children from the fairy tales of grandparents, neglecting a child or, as is usually the case in these stories, a stepchild, will have long-term negative consequences. However, in the author’s opinion, this seems to be, at least to some extent, what the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) has been doing thus far with the role of the switch-over rule (SOR) and permanent establishments in general under Pillar Two of the OECD. This can be seen particularly by the fact that, so far, only minimal information was provided on the concrete design and role of the SOR especially compared to the other three instruments under Pillar Two. The following contribution therefore aims at a more comprehensive examination of the SOR for GloBE purposes and how (low-taxed) permanent establishments are generally dealt with under the GloBE proposal. GloBE, GloBE proposal, switch-over rule, permanent establishment, Pillar Two, income inclusion rule, undertaxed payments rule, subject-to-tax rule, Blueprint, minimum tax.

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38

Lee, Taehee. "Base erosion and profit shifting by Google and platform market competition in Korea". SHS Web of Conferences 73 (2020): 01016. http://dx.doi.org/10.1051/shsconf/20207301016.

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The adoption of Google Taxes is often mentioned with respect to corporate taxes avoided for a MNE that does not have a permanent establishment in the domestic market. None has looked at the implications of avoided corporate taxes on platform market competition. Using Google as a representative MNE that employs the DIDS framework, the present study, using publicly disclosed financial statements information, documents that if a MNE with a permanent establishment in Korean market had generated profits of 520.9b KRW in 2017.

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39

Selezen, P. O. "NORMATIVE REGULATION OF BASIC PERMANENT ESTABLISHMENT IN TAX LEGISLATION OF UKRAINE". Legal horizons, n.º 17 (2019): 89–92. http://dx.doi.org/10.21272/legalhorizons.2019.i17.p:89.

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The basic permanent establishment has been used in the texts of bilateral double taxation treaties since the conclusion of the first ones in the second half of the XIX century. The article is aimed at the characterization of normative regulation of basic permanent establishment in the tax legislation of Ukraine in comparison with their conformity to the provisions of the OECD Model Tax Convention and its Commentaries. Reference to the OECD Model Tax Convention and its Commentaries as a basis for comparison is determined by the fact that it is a recognized and widely used source of interpretation of the provisions of double taxation treaties including the treaties concluded by Ukraine. The comparison of the provisions of the Tax Code of Ukraine and the OECD Model Tax Convention points out the existence of inconsistencies that might have a negative influence on the efficiency of the concept of a permanent establishment in Ukraine and good faith realization of conventional norms on tax matters in Ukraine. There are a few proposals of changes that might help to avoid the undesirable consequences of the abovementioned differences: 1) to replace the words “permanent place of activity” on “fixed place of activity” (Art. 14(1)(143) of the Tax Code of Ukraine); 2) to add the words “but not limited to” after the word “include” at the second part of Art. 14(1)(193) of the Tax Code of Ukraine; 3) to add the words “notwithstanding the provisions of the provisions of the first part of this Article” after the words “except to services of secondment of employees” and “civil rights and duties” at the second part of Art. 14(1)(193) of Tax Code of Ukraine; 4) to provide the mechanism of realization of provisions of Art. 10 of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS concluded in November 2016. Keywords: permanent establishment; OECD Model Tax Convention; tax legislation; double taxation treaties; interpretation.

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Peretiatkowicz, Lidia. "The Use of a Foreign Permanent Establishment in International Tax Planning". Zeszyty Naukowe Uniwersytetu Szczecińskiego Finanse Rynki Finansowe Ubezpieczenia 83 (2016): 119–27. http://dx.doi.org/10.18276/frfu.2016.5.83/1-11.

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Lee, Dongwook, Min Sung Kim, Yoon Kwon Nam, Dong Soo Kim y Seung Pyo Gong. "Establishment and Characterization of Permanent Cell Lines from Oryzias dancena Embryos". Fisheries and aquatic sciences 16, n.º 3 (30 de septiembre de 2013): 177–85. http://dx.doi.org/10.5657/fas.2013.0177.

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TAKAHASHI, MITSUAKI, MEGUMI KUMAI, NAOKI KANAI y TOKUJI UNNO. "Establishment and characterization of permanent human maxillary sinus carcinoma cell lines." Nippon Jibiinkoka Gakkai Kaiho 90, n.º 1 (1987): 21–27. http://dx.doi.org/10.3950/jibiinkoka.90.21.

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Koeppler, H., K. H. Pflueger, W. Knapp y K. Havemann. "Establishment of three permanent human leukaemia cell lines producing immunoreactive calcitonin". British Journal of Haematology 65, n.º 4 (abril de 1987): 405–9. http://dx.doi.org/10.1111/j.1365-2141.1987.tb04141.x.

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de Joliniere, J. "Human endometriosis-derived permanent cell line (FbEM-1): establishment and characterization". Human Reproduction Update 3, n.º 2 (1 de marzo de 1997): 117–23. http://dx.doi.org/10.1093/humupd/3.2.117.

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Barclay, P. "Does draft HMRC guidance trap non-residents with a 'permanent establishment'?" Trusts & Trustees 15, n.º 3 (9 de marzo de 2009): 129–30. http://dx.doi.org/10.1093/tandt/ttp015.

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Nakashima, M. "Establishment of primary cultures of pulp cells from bovine permanent incisors". Archives of Oral Biology 36, n.º 9 (1991): 655–63. http://dx.doi.org/10.1016/0003-9969(91)90018-p.

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Owen, Dylan, Allen P. Davis y Ahmet H. Aydilek. "Compost for Permanent Vegetation Establishment and Erosion Control along Highway Embankments". Journal of Irrigation and Drainage Engineering 147, n.º 8 (agosto de 2021): 04021031. http://dx.doi.org/10.1061/(asce)ir.1943-4774.0001587.

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Singh, Manoj Kumar. "Taxing E-Commerce on the Basis of Permanent Establishment: Critical Evaluation". Intertax 42, Issue 5 (1 de mayo de 2014): 325–33. http://dx.doi.org/10.54648/taxi2014034.

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This article discusses about concept of PE (Permanent Establishment) in case of E-commerce business transactions. Electronic commerce comprises the electronic sale by online stores of downloadable 'soft merchandise' such as music, e-books, e-newsletters, photos and video recordings, software and documents (direct e-commerce), the electronic ordering of tangible products (indirect e-commerce), online securities transactions as well as the provision of financial or other services. It also includes the subscription to and use of an internet service provider (ISP) or an online service provider (OSP), and has also been held to cover electronic data interchange (EDI), electronic fund transfers (EFT) and all credit and debit card activity. Ecommerce transactions can be 'business-to-business' (B2B) or 'business-to-consumer' (B2C). The principle difficulty with these kinds of transactions is that it is quite a challenge to identify the fixed place of business. Thus, tax administrations today, throughout the world face the formidable task of protecting their revenue bases without hindering the development of new technologies. The challenges that are being faced by the governments and organizations like the OECD are real and the focus is on how to address them collectively and by way of ensuring international consensus. The allocation of taxing rights must be based on mutually agreed principles and a common understanding of how these principles should be applied. In addition to the need for consensus between governments, a need for cooperation between governments and business has also been identified. The concept of PE is a fundamental and core aspect of international taxation. Its importance lies in its requirement to determine the right of a country to tax the profits of an enterprise that belongs to a different sovereign jurisdiction. Despite the two conventions and tax legislations in almost every country dealing with this concept, it yet remains elusive and its characterization gives rise to complex issues in international business taxation. Thus, there arises a need to not only clarify the concept but also to harmonize the varied interpretations given to PE worldwide through tax treaties, either by adding and reviewing the wording of Model Conventions such as the OECD, UN, and US versions, or by expanding the commentaries and technical explanations to them on current important matters.

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Persico, Giuseppe. "Agency Permanent Establishment under Article 5 of the OECD Model Convention". Intertax 28, Issue 2 (1 de febrero de 2000): 66–81. http://dx.doi.org/10.54648/262072.

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Dunahoo, Carol A. y Mary C. Bennett. "The Attribution of Profits to a Permanent Establishment: Issues and Recommendations". Intertax 33, Issue 2 (1 de febrero de 2005): 51–67. http://dx.doi.org/10.54648/taxi2005009.

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