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A "Home Office" may constitute a permanent establishment - Lexology
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The Ministry of Finance has published an EAS ruling dealing with the question of whether the home office of an employee resident in Austria may…
Extensive control of non-resident over Indian entity - A taxing...
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... (PE) of the Applicant in India and profits attributable to such PE were taxable as business profits as per Article 5 of Indian-Luxembourg DTAA.
Cliffe Dekker Hofmeyr - Indian revenue authority gets pole position...
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It was held that FOWC was liable to pay tax on the business income attributable to such PE in India. The relevant facts, key issues, arguments ...
Laws of the Territory of Michigan, Comprising the Acts, of a Public...
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such pe- oreditor. tition shall be made, or to the county court to which the justice
to ...
Cross-Border Taxation of Permanent Establishments: An International...
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A6: Generally, if the subcontractor is remunerated at arm's length then there will not be any additional profit attribution to such PE. While determining the profit ...
Dependent Agents as Permanent Establishments: Schriftenreihe IStR...
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Dependent Agents as Permanent Establishments The article on business profits may be the most relevant one in tax treaties. If patterned after the OECD Model...
New Licensing Guidance for PE Firms and Family Lexology
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— When considering a PE firm's application for a license for Type 9 regulated activity, the SFC expects such PE firm to be able to exercise ... › detail
Tribunal devises new approach for attribution of profits to PE -...
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The Delhi bench of the Income Tax Appellate Tribunal (
Structuring Venture Capital 2016e - LEVIN - Google Books
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Now, you can minimize your clients' tax liability and avoid legal pitfalls, as well as maximize returns on successful transactions and be prepared for all...
Handbook of Engineering and Specialty Thermoplastics, Volume 1:...
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Utilizes an encyclopedic approach to cover the developments in polyolefins and styrenics during the last decade This book focuses on common types of polymers...
Special Features of the UN Model Convention: Schriftenreihe IStR,...
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Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is...
The EU Common Consolidated Corporate Tax Base: Critical Analysis -...
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Under those rules, losses incurred by a foreign PE could be immediately offset in Germany, even if the profits of such PE were exempt pursuant to the applicable ...
Liquid Crystalline Polymers - Xin-Jiu Wang, Qi-Feng Zhou - Google...
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This textbook consists of six chapters. The first chapter highlights the concept of liquid crystals, including chemical structure, phase classification, defect...
Awwa Manual, Volume 55: Pe Pipe : Design and Installation - AWWA...
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This manual provides users of PE pipe and fittings in potable water systems with both technical and general information on design, specification, procurement,...
PE Pipe Design and Installation: M55
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As such, PE piping materials are designed in accordance with longer-term tests such as hydrostatic testing and testing for resistance to slow crack growth, which ...
Physical Education Teachers on Physical Education: A Sociological...
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As such, PE teachers' " philosophies” are prone to being value-laden, practical outlooks that represent an amalgam of various ideologies — featuring what I ...
Structuring Venture Capital, Edition (IL) - Levin, Rocap -...
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of. GP. Interest. Whether a service partner who receives a mere profits interest (such as a carried interest) recognizes taxable OI (either at the time such PE ...
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