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VOL. 6, ISSUE 3 (2024)
A study imposition of tax on permanent establishment and judicial approach: A case analysis
Authors
P Jogi Naidu
Abstract
A Permanent Establishment (PE) is a fundamental concept in
international tax law that establishes the tax obligations of a non-resident
entity within a host country. It refers to a fixed place of business through
which the business activities of an enterprise are wholly or partially carried
out. Understanding PE is crucial for attributing profits to foreign enterprises
and enabling the host country to levy taxes appropriately. The OECD Model Tax
Convention on Income and Capital, which serves as a foundation for bilateral
tax treaties, defines Permanent Establishment (PE) similarly in Article 5.
While the core concepts of Permanent Establishment (PE) such as Fixed Place PE,
Agency PE, and Construction PE have been elaborated, several other important
facets and nuances shape the understanding and application of PE in
international taxation. Additional aspects, including emerging issues related
to the digital economy, specific industry considerations, and
anti-fragmentation rules are elucidated.
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Pages:1-5
How to cite this article:
P Jogi Naidu "A study imposition of tax on permanent establishment and judicial approach: A case analysis". International Journal of Educational Research and Development, Vol 6, Issue 3, 2024, Pages 1-5
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