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.
Corporate counsel should combine deep technical knowledge with strategic dynamism, says Agarwal, winner of ITR’s EMEA In-house Indirect Tax Leader of the Year award
Ryan hopes the buyout will help it expand into Asia and the Middle East; in other news, three German finance ministers have called for a suspension of pillar two
Prudential had challenged HMRC over VAT group relief; in other news, Donald Trump unveiled timber and wood tariffs, and the European Commission published a ViDA implementation strategy