Tax treaties generally provide that the business profits of a non-resident enterprise are taxable in a state only to the extent that the non-resident enterprise has a permanent establishment (PE) in that state to which such profits are attributable. The PE definition included in tax treaties thus provides a crucial threshold to determine whether a non-resident enterprise must pay income tax on its business income in another state, explain Jacques Sasseville and Edward Barret.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
A global tax framework may not materialise anytime soon, but a common set of principles is becoming increasingly necessary, Rudolf Winkenius also tells ITR
While pillar two can progress without the US, it won’t reach the same heights without American involvement, argues Renáta Bláhová, founding partner of BMB Partners Taxand
The deal comes after PwC had accused Paul McNab of using confidential information; in other news, McDermott hired a new London tax head from a US rival
Looking at transfer pricing simplification is “obviously helpful”, but it should be done in line with current standards, a senior government figure reportedly said
Under the merged scheme for R&D tax relief introduced last year, rules on contracted out R&D have changed. James Dudbridge argues for a proactive approach when reviewing companies’ commercial arrangements