Recent Blog Articles


French and Spanish Courts reject the tax authorities’ attempts to attribute notional capital to permanent establishments of foreign banks
This article analyzes two important decisions in respect of a complex issue under tax treaty provisions similar to Art. 7(2) of OECD Model Convention...Read more

Interplay between Art. 7 and Art. 9 of the tax treaties: Why the Fujifilm decision seems questionable?
This article analyzes in detail as to whether the Source State's transfer pricing rules can apply in respect of the dealings between a permanent establishment and its head office...Read more

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Recent Presentations


Important Australian Decision On Place Of Effective Management: Is Location Of A Company's Board Meetings A Determinative Factor?
This presentation covers an important Australian decision on the issue of place of effective management...Read more

Could a shed for storing and repackaging products give rise to a PE? A Netherlands Supreme Court landmark decision
This presentation covers an important decision of the Netherlands Supreme Court, dealing with an issue concerning PE-exclusion provisions in the tax treaties...Read more

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COMMENTARY


  • Article 5 of Tax Treaties
      (Permanent Establishment)
  • Article 7 of Tax Treaties
      (Business Profits)
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