Permanent Establishments. A Domestic Taxation, Bilateral Tax Treaty and OECD Perspective

Permanent Establishments. A Domestic Taxation, Bilateral Tax Treaty and OECD Perspective will consist of two parts: Part One PE: The Legal and Compliance Setting. This section will feature a comprehensive and highly practical analysis of the concept of permanent establishment (PE), particularly as it s embodied in Article 5 of the Model Convention. In a departure from virtually all the current literature, the presentation will afford the reader a truly actionable tool they can use to optimise decision making as it relates to PE in a real world setting. The work would initially concentrate on the PE-related issues of most concern to corporate interests: the notion of PE and the allocation of profits. Part Two Country-specificPE profiles designed to facilitate the reader s decision making by allowing them to easily compare-and-contrast critical PE-related data over an array of key national jurisdictions. (Please see accompanying questionnaire outlining the issues covered.) Countries covered: Germany; -Hungary; India; -Italy; Japan; -Netherlands; Russia; -Spain; -Sweden; -Switzerland; -United Kingdom; -United States