Bibliografie tematiche / Permanent establishment

Letteratura scientifica selezionata sul tema "Permanent establishment"

Autore: Grafiati
Pubblicato: 4 giugno 2021
Ultima modifica: 25 aprile 2022

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Articoli di riviste sul tema "Permanent establishment"

1

de L’Hotellerie-Fallois, Domingo J. Jiménez-Valladolid. "The Permanent Establishment: Still a (Permanent) Requirement?" EC Tax Review 23, Issue 1 (1 febbraio 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 e Sangdo Lee. "Passive Partner and Permanent Establishment". Journal of IFA, Korea 26, n. 1 (febbraio 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 aprile 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 aprile 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 giugno 1997): 247–54. http://dx.doi.org/10.54648/taxi1997044.

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6

Van Schalkwyk, Linda, e Rozelle Van Schaik. "A critical analysis of the concepts ‘Permanent Establishment’ and ‘Foreign Business Establishment’". Journal of Economic and Financial Sciences 5, n. 1 (30 aprile 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. 3 (1 giugno 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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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 agosto 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. 11 (2017): 100–104. http://dx.doi.org/10.26425/1816-4277-2017-11-100-104.

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10

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

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Abstract (sommario):
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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Tesi sul tema "Permanent establishment"

1

Van, Schaik Rozelle. "A critical analysis of the concepts permanent establishment and foreign business establishment". Thesis, Stellenbosch : Stellenbosch University, 2010. http://hdl.handle.net/10019.1/21139.

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Thesis (MAcc)--Stellenbosch University, 2010.
ENGLISH ABSTRACT: The Income Tax Act, Act 58 of 1962 (‘the Act’) currently defines a permanent establishment in section 1. The definition of a permanent establishment in the Act refers to article 5 of the Model Tax Convention on Income and on Capital of the Organisation for Economic Co- Operation and Development. The existence of a permanent establishment in a tax jurisdiction determines the right of the jurisdiction to tax the profits of the permanent establishment. The concept foreign business establishment was inserted into section 9D of the Act by clause 10(1)(a) of the Revenue Laws Amendment Act, Act 59 of 2000. Section 9D is an antiavoidance provision, which determines that certain foreign-sourced income generated by South African controlled foreign companies are subject to tax in South Africa. The concept foreign business establishment is one of the exclusions from the anti-avoidance provisions in section 9D. The Revenue Laws Amendment Act, Act 59 of 2000, replaced all references to the concept permanent establishment with a reference to the newly introduced concept foreign business establishment in section 9D(9)(b) of the Act. The Explanatory Memorandum on the Revenue Laws Amendment Bill, 2000 (SARS 2000:1-12) does not provide a reason for the replacement of the concept permanent establishment. 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 Act. 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. It was found that the concepts permanent establishment and foreign business establishment are used in different contexts within the Act. The concepts also apply to different types of taxpayers in different situations. The two concepts have, however, the same objective, being the identification of criteria for the existence of legitimate and substantive business activities in the foreign tax jurisdiction. A comparison between the definitions of the two concepts reveals that there are various components in the definitions with the same wording and meaning. After a detailed comparison between the two definitions it was found that, subject to some 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 Act without having a material impact on the objective of section 9D(9)(b). This replacement is possible due to the mutual objective of and similar components contained in the definitions of the concepts permanent establishment and foreign business establishments.
AFRIKAANSE OPSOMMING: Die Inkomstebelastingwet, Wet 58 van 1962 (‘die Wet’) definieer ’n permanente saak in artikel 1. Die definisie van ’n permanente saak verwys na artikel 5 van die ‘Model Tax Convention on Income and on Capital of the Organisation for Economic Co-Operation and Development’. Die bestaan van ’n permanente saak in ’n belastingjurisdiksie bepaal die reg van die belastingjurisdiksie om die winste van die permanente saak te belas. Die begrip buitelandse besigheidsaak is deur artikel 10(1)(a) van die Wysigingswet op Inkomstewette, Wet 59 van 2000 in die Wet ingesluit. Artikel 9D is ’n teenvermydingsbepaling wat bepaal dat sekere inkomste vanaf ’n buitelandse bron gegenereer deur ’n Suid-Afrikaans beheerde buitelandse maatskappy in Suid-Afrika belas word. Die begrip buitelandse besigheidsaak is een van die uitsluitings van die teenvermydingsbepaling in artikel 9D. Alle verwysings in artikel 9D(9)(b) na die begrip permanente saak is deur die Wysigingswet op Inkomstewette, Wet 59 van 2000, vervang met ’n verwysing na die nuwe begrip buitelandse besigheidsaak. Die ‘Explanatory Memorandum on the Revenue Laws Amendment Bill, 2000’ (SARS 2000:1-12) verskaf nie ’n rede vir die vervanging van die begrip permanente saak nie. Die doel van die studie was om die begrippe permanente saak en buitelandse besigheidsaak te vergelyk sodat voorstelle gemaak kan word rakende die nodige byvoegings en wysings om die begrip buitelandse besigheidsaak met die internasionaal aanvaarde en erkende begrip, permanente saak, te vervang. Die voorgestelde vervanging van die begrip buitelandse besigheidsaak met ’n internasionaal aanvaarde en erkende begrip sal die internasionale verenigbaarheid van die Suid Afrikaanse wetgewing bevorder. Die gebruik van ’n begrip wat internasionaal aanvaar en erken word, sal sekerheid en duidelikheid bewerkstellig vir diegene wat deur die artikel geaffekteer word. Daar is bevind dat die begrippe permanente saak en buitelandse besigheidsaak in die Wet in verskillende verbande gebruik word. Die begrippe is ook van toepassing op verskillende belastingbetalers in verskillende situasies. Die twee begrippe het egter dieselfde doelwit naamlik die identifisering van kriteria vir die bestaan van wesenlike en volwaardige besigheidsaktiwiteite in die buitelandse belastingjurisdiksie. ’n Vergelyking tussen die definisies van die twee begrippe toon dat verskeie komponente van die definisies dieselfde woorde en betekenis bevat. Na ’n detail vergelyking van die twee begrippe is daar bevind dat, onderhewig aan sommige voorgestelde byvoegings en wysigings, die internasionaal erkende en aanvaarde begrip permanente saak die begrip buitelandse besigheidsaak in artikel 9D(9)(b) van die Wet kan vervang. Die vervanging is moontlik weens die gemeenskaplike doelwit en soortgelyke komponente in die definisies van die begrippe permanente saak en buitelandse besigheidsaak.
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2

Wepener, Suzette. "The impact of e-commerce on the permanent establishment definition". Master's thesis, University of Cape Town, 2016. http://hdl.handle.net/11427/20864.

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The main object of the concept of the definition of a permanent establishment in a double tax agreement is to set out the type and permanency of business activities that an entity must conduct before they can be subject to tax in another jurisdiction. Furthermore, the definition of a 'permanent establishment' as defined in article 5 of the OECD model tax convention requires the existence of a fixed place of business. This indicates the existence of a facility with a certain degree of permanence. The internet has changed the traditional international business model. It is no longer necessary that the entrepreneur, or his employees, agents, branches or intermediaries is in the country where the business is being conducted. It is clear that the internet overcomes the traditional limitations of physical presence in a jurisdiction when doing business. This poses a challenge when it comes to the determination of a 'permanent establishment', as the test is based on a physical presence of an entity in a jurisdiction. I want to determine if the current concept of a permanent establishment is still adequate to address the challenges posed by e-commerce. Taking into account that e-commerce was not a factor when the basis of the definition of the definition of a permanent establishment was formulated. The views of the OECD on e-commerce will be analysed to determine what they envisage and if they are of the opinion that the current definition is adequate to address the concept and reality of e-commerce and the taxation thereof. It is important to explore the views of the rest of the world on e-commerce and the taxation thereof. A multinational entity must be aware of the tax presence it can create in a foreign country, especially when it comes to creating a permanent establishment in that foreign country. It is my aim to identify and discuss the challenges and difficulties e-commerce poses when determining the existence of a permanent establishment and also to research certain adaptions and recommendations of the current taxing system and relevant guidelines.
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Andersson, Niclas. "Attributing Free Capital and Profit to Permanent Banking Establishments". Thesis, Internationella Handelshögskolan, Högskolan i Jönköping, IHH, Rättsvetenskap, 2010. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-14007.

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By September 2010, in its ongoing effort to clarify the subject of taxing a permanent establishment, the OECD launched a new article 7 in its model tax convention together with a revised version of the report on the attribution of profits to permanent establishments. The article and the report contain a new order of taxation, where a permanent establishment should, in almost all aspects, be treated as a separate entity. The question is if the new approaches, methods and solutions provided by the article and the report will prove effective against double taxation. The thesis has studied this by analysing and then comparing the OECD’s authorised approach with the relevant literature and the current practical situation. The result of the thesis presents that there are problems with the approaches and methods, which in some situations will cause double taxation, not the least regarding allocation of Free Capital. The thesis also concludes that the way in which article 7 of the model tax convention tries to solve double taxation without unnecessary use of the mutual agreement procedure is flawed in relation to differences in national legislation.
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Rudelius, Linda. "The Scope of Marks & Spencer : The applicability to permanent establishments". Thesis, Jönköping University, JIBS, Commercial Law, 2009. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-11059.

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The European Union (EU) is built on the principle of freedom of establishment, meaning that companies have the possibility to establish themselves as a company or by setting up a secondary establishment in other Member States. This right has been confirmed by the European Court of Justice through case law.

A basic feature in domestic tax legislation is that losses are allowed to be set off against profits when calculating the tax liability of a company. At the moment cross-border loss compensation within the EU is restricted, unfeasible or just accepted on a temporary basis. This lack of recognition of loss-offset gives the fact that double taxation may occur and claims form two or more national tax systems leads to uncertainty in the way a company will be taxed. Depending on whether the secondary establishment is a subsidiary or a branch, the rules relating to loss compensation differs.

Taxation of secondary establishments is based on the principle of whether or not they are considered as a resident or a non-resident of the state. In regards to taxation of secondary establishments, the PE is considered to be a non-resident and a subsidiary considered to be a resident. However, the European Court of Justice approach of non discriminatory treatment and equal treatment that has been developed and seen in the history of case law leads to the question if the Marks & Spencer ruling that concerned secondary establishments in form of subsidiaries can be applied to permanent establishments.

The most vital difference between a subsidiary and a permanent establishment is connected to the taxation of the two. The subsidiary is considered to become a resident of the establishing state while the permanent establishment is seen as a non-resident. This legal difference between the two leads to different treatment under tax law. Taxation under a tax treaty leads to the situation where one of the contracting states will either credit or exempt the income deriving from the permanent establishment. Permanent establishments are often taxed under the method of exemption.

In the Marks & Spencer case it was held that losses and profits were two sides of the same coin. Applying this statement to permanent establishments gives the notion that if a contracting state exempts an income, there will be a set off of the symmetry of having losses and profits within the same tax system. This lead to the fact that if applying the Marks & Spencer ruling on permanent establishments that are taxed under the exemption method, allowing terminal losses to be taken into account at the head office will set off the symmetry. Therefore it can be considered as the Marks & Spencer ruling shall not apply to permanent establishments.

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Sjöberg, Daniel. "Permanent Establishment : With respect to attribution of income and the question of documentation of internal dealings". Thesis, Internationella Handelshögskolan, Högskolan i Jönköping, IHH, Rättsvetenskap, 2011. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-15886.

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In 2008 the Committee of Fiscal Affairs of OECD published its report on profit attributable to a permanent establishment. In 2010 article 7 of the OECD model tax convention was reformed, and the report was revised to better conform to the article. The authorised OECD approach is that a permanent establishment is a separate and independent entity, engaged in the same or similar activities under the same or similar conditions, taking into account the functions performed, assets used and risks assumed by the enterprise through the permanent establishment and through other parts of the enterprise. The approach is built on a two step analysis, the first is a functional and factual analysis and the second is determining the income of the permanent establishment. The authorised OECD approach is that the Transfer Pricing Guidelines should be applied by analogy in transactions between the permanent establishment and the rest of the enterprise. The Swedish Income Tax Law has the view that the permanent establishment is a separate and independent entity. The Swedish approach is a two step analysis; the basis is the accountings of the enterprise adjusted for internal dealings, and the second step is a functional analysis. The Swedish law does not allow allocation of “free” capital to a permanent establishment, nor does it allow a permanent establishment to deduct royalty payments to other parts of the enterprise. The Swedish provision regarding documentation of transactions between enterprises with economic interest in each other does not apply to permanent establishments. For reasons of certainty and predictability, the best thing would be for the legislator to reform the Swedish Income Tax Law. Seeing that a permanent establishment is obliged to have its own accounting, the burden and cost of obliging it to document internal dealings would not be that big.
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Soliman, Hanya. "The establishment of a permanent international criminal court, a critical analysis of opposing theoretical views". Thesis, National Library of Canada = Bibliothèque nationale du Canada, 2000. http://www.collectionscanada.ca/obj/s4/f2/dsk2/ftp03/MQ52369.pdf.

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Soliman, Hanya Carleton University Dissertation Law. "The Establishment of a permanent International Criminal Court; a critical analysis of opposing theoretical views". Ottawa, 2000.

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Hietala, Sanna. "Assignments abroad : Determining when they constitute a permanent establishment for a foreign enterprise in the host country". Thesis, Internationella Handelshögskolan, Högskolan i Jönköping, IHH, Redovisning och Rättsvetenskap, 2014. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-24718.

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Hasanbegovic, Jasmina. "Attribution of Profits to Dependent Agent Permanent Establishments : The dual taxpayer approach versus the single taxpayer approach". Thesis, Jönköping University, JIBS, Commercial Law, 2009. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-11417.

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Business profits constitute the main part of income derived through international business and these profits are only to be taxed in the home state of the enterprise. However, if the enterprise conducts business in a host state through a PE, the profits attributable to the PE are taxable in the host state. Article 7 of the OECD Model Tax determines the profits attributable to the PE.

Nevertheless, Member States have interpreted Article 7 of the OECD Model Tax Convention in various ways. In order to provide consensus the OECD adopted an authorised OECD approach for attributing profits to PEs.

The first part of the purpose of this thesis is to study the Swedish approach for attributing profits to dependent agent PEs in relation to the authorised OECD approach. An enterprise from the home state can be considered to have a dependent agent PE in the host state if it conducts business in the host state through a dependent agent located therein. This is provided that the agent has the authority to conclude contracts in the name of the enterprise and exercises this authority regularly.

Under the authorised OECD approach for profit attribution to dependent agent PEs it is possible to allocate profits to the PE in excess of the arm’s length remuneration paid to the dependent agent. Thereby, the OECD has adopted the dual taxpayer approach as the authorised OECD approach.

According to the author’s opinion the Swedish perspective regarding profit attribution to dependent agent PEs differs from the authorised OECD approach as the dual taxpayer approach so far has not been applied in Sweden. Furthermore, it differs as the attribution of capital to PEs is not allowed according to case law and as far as the recognition of internal dealings is concerned.

When the OECD adopted the dual taxpayer approach as the authorised OECD approach another method was available; the single taxpayer approach. In line with this approach no further profits in excess of the arm’s length remuneration to the dependent agent can be attributed to the dependent agent PE. However, the single taxpayer approach was rejected as the authorised OECD approach, which has lead to disagreement within the international tax community.

Therefore, the second part of the purpose of this thesis is to study to what extent the authorised OECD approach is sustained. This is done by analysing reactions to the single and dual taxpayer approach among business and academic circles.

The author believes that reactions against the dual taxpayer approach mainly arise in situations when an enterprise in the host state gives rise to a dependent agent PE. Therefore, the authorised OECD approach should have recognised that different types of dependent agent PEs might arise and the approach is only sustained to the extent that a person belonging to the foreign enterprise leads to the existence of a dependent agent PE.

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Young, Nikita Jade. "The effect of global e-commerce on taxation legislation and the permanent establishment concept in South Africa". Thesis, Rhodes University, 2013. http://hdl.handle.net/10962/d1001608.

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The objective of this thesis was to analyse the effect of the increasing popularity of global e-commerce on the South African legislative framework in respect of the taxation of non-resident enterprises, and to propose a possible solution for the taxation of e-commerce, taking into account previous theories. The methodology utilised comprised of a critical analysis of the legal rules relating to the taxation of a foreign entity's business profits by virtue of the application of the permanent establishment principle, its definition and evolution as a conceptual basis for taxation. Furthermore, an in depth evaluation of the various solutions that have already been proposed and, in some cases, implemented was undertaken. It was concluded that the application of the permanent establishment principle is wholly ineffective as a means to levy tax on the e-commerce business profits of a foreign entity as the principle relies too heavily upon a physical intermediary in the source state, whereas e-commerce transactions are conducted on the intangible trading platform of the Internet. In light of the numerous policy proposals advanced over the years, it was concluded that the most feasible and practical solution for the taxation of foreign e-commerce would be the imposition on a foreign entity in South Africa of a low withholding tax on the active business profits in excess of a pre-determined threshold. Key words: South African taxation; e-commerce; foreign business entity; permanent establishment; withholding tax
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Più fonti

Libri sul tema "Permanent establishment"

1

How fixed is a permanent establishment? Alphen aan den Rijn, The Netherlands: Kluwer Law International, 2013.

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2

Skaar, Arvid Aage. Permanent establishment: Erosion of a tax treaty principle. Deventer: Kluwer Law and Taxation Publishers, 1991.

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3

Byler, James W. Establishment report: Permanent plots to evaluate the effects of Armillaria root disease in precommercially thinned stands. Missoula, Mont: United States Dept. of Agriculture, Forest Service, Northern Region, State & Private Forestry, 1985.

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4

Kegley, Sandy. Establishment report for dougls-fir [i.e. douglas-fir] tussock moth permanent plots on the Clearwater National Forest. Missoula, MT: USDA Forest Service, Northern Region, 2003.

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5

Williams, Robert L. Fundamentals of permanent establishments. The Hague, The Netherlands: Wolters Kluwer Law & Business, 2014.

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6

Dependent agents as permanent establishments. Wien: Linde, 2014.

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7

John, Huston. Permanent establishments: A planning primer. Deventer: Kluwer Law and Taxation Publishers, 1993.

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8

Hentschel, Sven. The Taxation of Permanent Establishments. Wiesbaden: Springer Fachmedien Wiesbaden, 2021. http://dx.doi.org/10.1007/978-3-658-34000-1.

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Watch, Human Rights. Afghanistan's Bonn Agreement one year later: A catalog of missed opportunities. New York: Human Rights Watch, 2002.

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10

Great Britain. Parliament. House of Commons. European Scrutiny Committee. Fourth report together with the proceedings of the Committee on January 2001: Documents considered by the Committee including: Community postal services(10544/00), Establishment of permanent CESDP bodies. London: Stationery Office, 2001.

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Capitoli di libri sul tema "Permanent establishment"

1

Nuggehalli, Nigam. "Permanent Establishment". In International Taxation, 29–46. New Delhi: Springer India, 2019. http://dx.doi.org/10.1007/978-81-322-3670-2_4.

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Phillips, John S. "Permanent Establishment". In Tax Treaty Networks 1991, 121–66. London: Routledge, 2021. http://dx.doi.org/10.4324/9781315075631-6.

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3

Riccardi, Lorenzo. "Anti-Avoidance Rules and Permanent Establishment Concept". In Chinese Tax Law and International Treaties, 103–9. Heidelberg: Springer International Publishing, 2013. http://dx.doi.org/10.1007/978-3-319-00275-0_8.

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Neitzel, Heidemarie. "Establishment of Permanent Growing Lymphoblastoid Cell Lines". In Diagnostic Cytogenetics, 121–31. Berlin, Heidelberg: Springer Berlin Heidelberg, 1999. http://dx.doi.org/10.1007/978-3-642-59918-7_6.

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Parrilli, Davide Maria. "Grid and Taxation: The Server as Permanent Establishment in International Grids". In Lecture Notes in Computer Science, 89–102. Berlin, Heidelberg: Springer Berlin Heidelberg, 2008. http://dx.doi.org/10.1007/978-3-540-85485-2_7.

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Montserrat, Hermosin Alvarez. "The Permanent Establishment The Crisis of an Institution in The Digital Economy". In WCLF Tax und IP Gesprächsband 2019, 37–58. Wiesbaden: Springer Fachmedien Wiesbaden, 2021. http://dx.doi.org/10.1007/978-3-658-32073-7_4.

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Lo, Chang-fa. "On the Establishment of a Regional Permanent Mediation Mechanism for Disputes Among East and Southeast Asian Countries". In Economics, Law, and Institutions in Asia Pacific, 335–51. Singapore: Springer Singapore, 2016. http://dx.doi.org/10.1007/978-981-10-1995-1_20.

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Hentschel, Sven. "G. Conclusion". In The Taxation of Permanent Establishments, 423–28. Wiesbaden: Springer Fachmedien Wiesbaden, 2021. http://dx.doi.org/10.1007/978-3-658-34000-1_7.

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Hentschel, Sven. "B. Overarching Principles of Tax Policy". In The Taxation of Permanent Establishments, 15–37. Wiesbaden: Springer Fachmedien Wiesbaden, 2021. http://dx.doi.org/10.1007/978-3-658-34000-1_2.

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Hentschel, Sven. "E. Digitalisation of the Economy and Its Implications for the PE Concept". In The Taxation of Permanent Establishments, 309–59. Wiesbaden: Springer Fachmedien Wiesbaden, 2021. http://dx.doi.org/10.1007/978-3-658-34000-1_5.

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Atti di convegni sul tema "Permanent establishment"

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Broms, Bengt. "ESTABLISHMENT OF THE PERMANENT INTERNATIONAL CRIMINAL COURT". In Proceedings of the Forty-Eighth Pugwash Conference on Science and World Affairs. WORLD SCIENTIFIC, 2001. http://dx.doi.org/10.1142/9789812810212_0049.

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Wang, Jiahui, Mingyu Wang, Dafang Wang e Qi Li. "Establishment of Electromagnetic Model of Permanent Magnet Synchronous Motor for Electric Machine Emulator". In 2021 International Conference on Control Science and Electric Power Systems (CSEPS). IEEE, 2021. http://dx.doi.org/10.1109/cseps53726.2021.00070.

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Kovač, Matjaž. "Analysis of Taxation of Income-Related To Permanent Establishment According To the OECD Model". In 3rd International Conference on Research in Business, Management and Economics. GLOBALKS, 2020. http://dx.doi.org/10.33422/3rd.icrbme.2020.11.110.

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Yanliang, Xu, e Xin Feng. "Model Establishment and Parameter Calculation of Permanent Magnet-Biased Hybrid Magnetic Bearing with Magnet in Rotor". In 2007 2nd IEEE Conference on Industrial Electronics and Applications. IEEE, 2007. http://dx.doi.org/10.1109/iciea.2007.4318366.

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Kerdtuad, Paiwan, Thawatchai Simma, Kunjana Chaiamarit e Soupagorn Visawaphatradhanadhorn. "Establishment of a Pico Hydro Power Plant Using Permanent Magnet Synchronous Generator Supplied for AC Microgrid". In 2018 International Electrical Engineering Congress (iEECON). IEEE, 2018. http://dx.doi.org/10.1109/ieecon.2018.8712214.

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Dunlap, R. A., e C. J. Purcell. "A Magnetostrictive Sonar Projector Utilizing a Terfenol Driver". In ASME 1995 Design Engineering Technical Conferences collocated with the ASME 1995 15th International Computers in Engineering Conference and the ASME 1995 9th Annual Engineering Database Symposium. American Society of Mechanical Engineers, 1995. http://dx.doi.org/10.1115/detc1995-0442.

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Abstract Defence Research Establishment Atlantic (DREA) is developing a flextensional barrel-stave projector which utilizes a magnetostrictive Terfenol-D driver. Our attention has focussed on three critical aspects of the design of the projector: (1) reduction of eddy currents, (2) incorporation of permanent magnets to bias the Terfenol and (3) a low reluctance magnetic flux return path. Here we describe a projector design which deals with these three aspects. The Terfenol rod is sectioned radially in order to reduce eddy current losses. Co-Sm permanent magnets are used to provide the magnetic bias field to the Terfenol. The magnetic flux return path is comprised of ferrite disks at the ends of the drive rod and a high permeability cylinder constructed of Metglas 2605TCA. The total projector mass is 3.85 kg. In water the resonance occurs at approximately 1.0 kHz and the bandwidth is 310 Hz. At resonance the distortion limited source level was measured to be 197.7 dB re 1μPa@ 1m and the efficiency was 32.3%.
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Allapitchai, M. Shahril Majid, Ahmad Luqman Johan, El Khalil Mohamed M’Bareck Heboul, Sattiyaraju Sellapan, William Sin Yoong Liew, Ahmad Hafizi Ahmad Zaini, Mohd Hairi Abdul Razak e M. Yuzmanizeil Yaakub. "Annulus Perforate, Wash and Cement : Establishing Barrier Verification Process for Deepwater Subsea Wells Abandonment and Its Lessons Learnt". In SPE Symposium: Decommissioning and Abandonment. SPE, 2021. http://dx.doi.org/10.2118/208492-ms.

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Abstract Wells plug & abandonment was carried out in a deepwater field (Field C) offshore West Africa. There were 15 deepwater subsea wells, in this field. Thirteen of the wells were completed with Open Water Vertical Xmas Tree (OXT) while remaining two were completed with Enhanced Vertical Xmas Tree (EVXT). All the wells were permanently abandoned with permanent barriers established in accordance to Norsok D-010, rev. 2013. This involved establishing well barriers which would both horizontally and vertically effective. The operator evaluated several methods in establishing well barriers for the permanent abandonment purpose of these 15 wells. The barriers placement for areas with good annulus cement were straightforward as an internal cement plug could be spotted as a permanent barrier. For this particular field, it is noted that all of the 15 wells have hydrocarbon bearing and permeable formations above the top of expected annulus lead cement which is designed basically to manage ECD during cementing job rather than giving good annular isolation. Due to this, it is important for the operator to employ the best technique that could establish a permanent cement barrier both inside the casing and in the annulus at the same time. Operator learned that Section Milling was the widely accepted method to establish barrier in cases where there is poor cement or the annulus cement is not present particularly in land and offshore wells. However, this technique poses severe operational risk especially in a deepwater operation mode. Upon review, it was determined that Perforate, Wash and Cement (PWC) technology has been proven and it would become a valuable technique in establishing well barrier which complies with abandonment requirement as per the industry guidelines. High risk activities for deepwater operations such as section milling could be avoided by employing this method. Nonetheless, the Perforate, Wash and Cement (PWC) technology has its own set of risks especially with its method of establishing the well barrier immediately upon setting it. This involves drilling and re-logging the well immediately after setting the cement in annulus to prove the barrier. Upon discussion with PWC contractor, it was agreed that the verification technique may create additional hazards as it could jeopardize the integrity of the installed barrier in the annulus. The additional requirement for cement verification process will also prolong the project duration, hence is an additional cost to the project too. Operator worked together with the Perforate Wash and Cement (PWC) Contractor and Well Examiner to determine the best verification method for PWC plugs with the objective to comply with regulation on cement verification while at the same time, resulting in most cost-efficient and time-efficient operation. The establishment of Element Acceptance Criteria as an alternative Barrier Verification Process for PWC technology is necessary to improve the reliability of the system as well as reducing associated risks. In total, 18 PWC operations were successfully carried out throughout the campaign. An extensive after action review was conducted at the completion of each job to capture the valuable lessons learnt. These lessons learnt are shared in this paper as well which could add value for future operations with similar settings. It is expected that this paper will serve as a reference in the establishment of Element Acceptance Criteria as well as its implementation during the P&A campaign. It is hoped that the lessons learnt shared in the paper could assist other Operators on planning for similar campaigns in the future.
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Ko, Hyun Seok, Yong Min Kim, Young Wook Lee, Dong Hoon Shin, Young Ho Cho e Chang Sun Kang. "Establishment of Korean Nuclear Ombudsman System Importing Compensation and Insurance Concept for Residents". In 14th International Conference on Nuclear Engineering. ASMEDC, 2006. http://dx.doi.org/10.1115/icone14-89725.

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In Korea, the nuclear power generation is grown technically well. Already, 20 nuclear reactors are operated, and approximate they supply the 40% of whole the consumption of electric power. This is the driving force of Korean industrial development. Besides, Korean Standard Nuclear Power Plant that was developed by Korean self-technique with nuclear plant technique independence, Ul-Chin 6 has started the commercial operation. Advanced Korean Standard Nuclear Power Plant, new Gori 1, 2 constructions are commenced. But, past days Korean situation is that intention of residents is neglected in the decision making process of nuclear power plant construction and operation. In existing decision making process, it is regarded as the role of public opinion is secondary, and the problem of decision making process is that public is persuaded and believed. So, in decision making process, the public opinion is considered restrictively, there is not the actual public participation. Therefore the dissatisfaction of public is increased continuously, and in Korea, bad recognition about nuclear power is getting full. The method of public participation for complement of this problem is public hearing or ombudsman system. The public hearing is ensuring public participation before decision of a case, and ombudsman is the system that elevates the public satisfaction through continuous feedback of public requirement to occur in deciding and performing the matters. In Korean situation, that present 20 nuclear reactors are operated and also the place of radioactive waste repository has been decided, not only the introduction of public hearing to decide the coming matter but also the operation of ombudsman system to continuously correct and collect the public requirements about the matter to already decided and operated is necessary. In Korea, administration type ombudsman is operated now. But, it has operated without basic element at the aspect of organization, function and phase. So it is not established a firm phase as right relief body to be believed by public with lack of independence, authority and specialty. Therefore the establishment of organization that can be the role as special ombudsman organization about sensitive and special matter like nuclear matter is necessary. Definite establishment element of ombudsman system is to introduce of congress type ombudsman element, to be permanent standing system ombudsman, to limit jurisdiction extent and have strong authority, to be able to access easily, to be composed of legal and nuclear specialist. One of important requirements of resident is compensation. So, based on the resident compensation theory about aversion equipment, ombudsman system should be established introducing the insurance theory through risk management as functional background for appropriate compensation.
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Karatalov, Omurbek. "Open Economy and Economic Integration within the Framework of Eurasia". In International Conference on Eurasian Economies. Eurasian Economists Association, 2013. http://dx.doi.org/10.36880/c04.00633.

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The Kyrgyz Republic economy openness is studied within the framework of the Eurasia. Insufficient level of the financial and economic standing of Kyrgyzstan is clarified. Reasons for Governmental regulating use in the area of monetary, tax and budget policy in USA have been set up. Conditions of the development of industrial countries economy are under consideration. The necessity of financialisation of all capital of country is defined. Kyrgyzstan public budget’s permanent deficiency formation reasons are studied. A necessity of integration economic relations development within the framework of Eurasia is offered. A necessity of sustainable economic relations establishment as well as finding solution for external debt between Kyrgyzstan and Russia have been justified. It is recommended to strengthen effective fight against a scale corruption, «shadow» economy and criminalization of economy and finances. The increase of efficiency and responsibility of top managers of the public administration level have been offered. The necessity of the independent mastering of own gold-mining fields is justified. The need to attract the foreign direct investments to the area of mining and processing industry have been offered. Within the framework of acceleration of economic integration. Needs for the development of exploring and processing of hydrocarbons as well as building of large economic entities especially the hydroelectric power stations, namely Kambar-Ata-1 Hydro-Power Plants have been suggested. By this it is also suggested to Russia to develop this as strategic partner of Kyrgyzstan. Creation of integral customs system and energy cooperation suggested. It should be supported by establishment of unique equivalent among Eurasia states. By this it is to be possible to find acceptable solutions in finance and economy and to form a united economic cooperation considering a sovereignty of each state. It is necessary to develop the identical financial reporting of point-of-sale and payment balances, balance of international investments, compliable national republics and on the whole on Eurasia. To walk away from the calculation and actual use of dollar of the USA in finance and economic operations. Based on econometric prognosis of gross internal product and the public budget of Kyrgyzstan is made calculating on the per to 2025 year.
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FRENCH, J. "Establishment and support of a permanently staffed Mars outpost". In 27th Aerospace Sciences Meeting. Reston, Virigina: American Institute of Aeronautics and Astronautics, 1989. http://dx.doi.org/10.2514/6.1989-514.

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Rapporti di organizzazioni sul tema "Permanent establishment"

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Dietz, Neil. Establishment of a Permanent Campus for the Seafarers Training Center of the Paul Hall Institute for Human Development, in Kalaelova, Hawaii. Fort Belvoir, VA: Defense Technical Information Center, giugno 2006. http://dx.doi.org/10.21236/ada455058.

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Gellici, J. A., e C. E. Gawne. Hydrogeologic investigation and establishment of a permanent multi-observational well network in Aiken, Allendale, and Barnwell Counties, South Carolina. Phase VIII. Office of Scientific and Technical Information (OSTI), febbraio 1996. http://dx.doi.org/10.2172/239303.

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Gellici, J. A., R. H. Reed, W. R. Logan, R. K. Aadland e G. C. Simones. Hydrogeologic investigation and establishment of a permanent multi-observational well network in Aiken, Allendale, and Barnwell Counties, South Carolina. Eight-year interim report (1986-1994). Volume 1 cluster-site description. Office of Scientific and Technical Information (OSTI), maggio 1995. http://dx.doi.org/10.2172/70740.

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Millán-Narotzky, Lucas, Javier García-Bernado, Maïmouna Diakité e Markus Meinzer. Tax Treaty Aggressiveness: Who is Undermining Taxing Rights in Africa? Institute of Development Studies (IDS), novembre 2021. http://dx.doi.org/10.19088/ictd.2021.015.

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Tax avoidance strategies by multinational companies rely heavily on tax treaties. Multinational companies can relocate financial activities across countries to ensure the applicability of the most beneficial tax treaties. This ‘treaty shopping’ can be particularly harmful to African countries, impairing their efforts for domestic resource mobilisation and achieving sustainable development goals. In this paper, we analyse the aggressiveness of tax treaties towards African countries – the extent to which signing tax treaties reduces the taxing rights of African governments. We find that treaties signed with France, Mauritius and the United Arab Emirates reduce withholding tax rates the most, while treaties signed with European countries – and, in particular, the United Kingdom and France – greatly limit other taxing rights, for example, by restricting the scope of permanent establishment definition.
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Financial Stability Report - Second Semester of 2020. Banco de la República de Colombia, marzo 2021. http://dx.doi.org/10.32468/rept-estab-fin.sem2.eng-2020.

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The Colombian financial system has not suffered major structural disruptions during these months of deep economic contraction and has continued to carry out its basic functions as usual, thus facilitating the economy's response to extreme conditions. This is the result of the soundness of financial institutions at the beginning of the crisis, which was reflected in high liquidity and capital adequacy indicators as well as in the timely response of various authorities. Banco de la República lowered its policy interest rates 250 points to 1.75%, the lowest level since the creation of the new independent bank in 1991, and provided ample temporary and permanent liquidity in both pesos and foreign currency. The Office of the Financial Superintendent of Colombia, in turn, adopted prudential measures to facilitate changes in the conditions for loans in effect and temporary rules for rating and loan-loss provisions. Finally, the national government expanded the transfers as well as the guaranteed credit programs for the economy. The supply of real credit (i.e. discounting inflation) in the economy is 4% higher today than it was 12 months ago with especially marked growth in the housing (5.6%) and commercial (4.7%) loan portfolios (2.3% in consumer and -0.1% in microloans), but there have been significant changes over time. During the first few months of the quarantine, firms increased their demands for liquidity sharply while consumers reduced theirs. Since then, the growth of credit to firms has tended to slow down, while consumer and housing credit has grown. The financial system has responded satisfactorily to the changes in the respective demands of each group or sector and loans may grow at high rates in 2021 if GDP grows at rates close to 4.6% as the technical staff at the Bank expects; but the forecasts are highly uncertain. After the strict quarantine implemented by authorities in Colombia, the turmoil seen in March and early April, which was evident in the sudden reddening of macroeconomic variables on the risk heatmap in Graph A,[1] and the drop in crude oil and coal prices (note the high volatility registered in market risk for the region on Graph A) the local financial markets stabilized relatively quickly. Banco de la República’s credible and sustained policy response played a decisive role in this stabilization in terms of liquidity provision through a sharp expansion of repo operations (and changes in amounts, terms, counterparties, and eligible instruments), the purchases of public and private debt, and the reduction in bank reserve requirements. In this respect, there is now abundant aggregate liquidity and significant improvements in the liquidity position of investment funds. In this context, the main vulnerability factor for financial stability in the short term is still the high degree of uncertainty surrounding loan quality. First, the future trajectory of the number of people infected and deceased by the virus and the possible need for additional health measures is uncertain. For that reason, there is also uncertainty about the path for economic recovery in the short and medium term. Second, the degree to which the current shock will be reflected in loan quality once the risk materializes in banks’ financial statements is uncertain. For the time being, the credit risk heatmap (Graph B) indicates that non-performing and risky loans have not shown major deterioration, but past experience indicates that periods of sharp economic slowdown eventually tend to coincide with rises in non-performing loans: the calculations included in this report suggest that the impact of the recession on credit quality could be significant in the short term. This is particularly worrying since the profitability of credit establishments has been declining in recent months, and this could affect their ability to provide credit to the real sector of the economy. In order to adopt a forward-looking approach to this vulnerability, this Report presents several stress tests that evaluate the resilience of the liquidity and capital adequacy of credit institutions and investment funds in the event of a hypothetical scenario that seeks to simulate an extreme version of current macroeconomic conditions. The results suggest that even though there could be strong impacts on the credit institutions’ volume of credit and profitability under such scenarios, aggregate indicators of total and core capital adequacy will probably remain at levels that are above the regulatory limits over the horizon of a year. At the same time, the exercises highlight the high capacity of the system's liquidity to face adverse scenarios. In compliance with its constitutional objectives and in coordination with the financial system's security network, Banco de la República will continue to closely monitor the outlook for financial stability at this juncture and will make the decisions that are necessary to ensure the proper functioning of the economy, facilitate the flow of sufficient credit and liquidity resources, and further the smooth operation of the payment systems. Juan José Echavarría Governor
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