Overview

permanent establishment


'permanent establishment' can also refer to...

permanent establishment

permanent establishment

permanent establishment

permanent establishment

permanent establishment

permanent establishment

permanent establishment

Does draft HMRC guidance trap non-residents with a ‘permanent establishment’?

Human endometriosis-derived permanent cell line (FbEM-1): establishment and characterization

Treaty between Guatemala and the United States for the Establishment of a Permanent Commission of Enquiry, signed at Washington, 20 September 1913

Treaty between Honduras and the United States for the Establishment of a Permanent Commission of Enquiry, signed at Washington, 3 November 1913

Treaty between Bolivia and the United States for the Establishment of a Permanent Commission of Enquiry, signed at Washington, 22 January 1914

Treaty between Portugal and the United States for the Establishment of a Permanent Commission of Enquiry, signed at Lisbon, 4 February 1914

Treaty between Costa Rica and the United States for the Establishment of a Permanent Commission of Enquiry, signed at Washington, 13 February 1914

Treaty between the United States and Venezuela for the Establishment of a Permanent Commission of Enquiry, signed at Caracas, 21 March 1914

Treaty between Denmark and the United States for the Establishment of a Permanent Commission of Enquiry, signed at Washington, 17 April 1914

Convention between the Netherlands and the United States for the Establishment of a Permanent Commission of Enquiry, signed at Washington, 18 December 1913

Treaty between Italy and the United States for the Establishment of a Permanent Commission of Enquiry, signed at Washington, 5 May 1914

Treaty between Norway and the United States for the Establishment of a permanent Commission of Enquiry, signed at Washington, 24 June 1914

 

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Most tax treaties operate so that business profits are taxed in the country of the taxpayer’s residence, unless the taxpayer has a ‘permanent establishment’ in the other territory. In the model double taxation agreement drawn up by the Organization for Economic Cooperation and Development, a permanent establishment is defined as a ‘fixed place of business through which the business of an enterprise is wholly or partly carried on’. The model agreement goes on to state specifically that the term ‘permanent establishment’ includes a place of management, branch, office, factory, workshop, mine, oil or gas well, quarry, or any other place of extraction of natural resources.

Subjects: Accounting.


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