Acerbis, FabrizioNuzzolo, Francesco
Includes guidance on registration, tax periods, taxable profits, and allocated expenses February 19, 2025 The State Tax Inspectorate on December 16, 2024, released commentary on the definition of permanent establishment (PE) under income tax treaties, and also providing guidance on registration, ta...
However, the foregoing example leads to a conflict of the right of taxation, based on the national, German definition of a permanent establishment, which defines a right of taxation in Germany as well. The before mentioned conflict also applies for income taxes, wage taxes and value added taxes...
A permanent establishment is a fixed place of business through which a non-resident company carries out all, or part, of its primary activities in Italy. The definition of a permanent establishment is outlined inArticle 162 of the Consolidated Income Tax Act (TUIR). This legislation was later ...
EN: Permanent Establishment. 3. Industrial Code of Prussia, 17 Jan. 1845, Sec. 26, see Prussian statute book 41 (1845). 4. Cf.Kolck, Der Betriebsstättenbegriff im nationalen und internationalen Steuerrecht, 15;Skaar, Permanent Establishment—Erosion of a Tax Treaty Principle, 76. ...
rules applicable in conventional tax law, in particular with regard to determining the conditions for qualifying a “building site or construction or installation project” as a permanent establishment (hereafter “PE”), as defined by the OECD Model Tax Convention on Income and on Capital (...
Residential care homemeans any home, establishment, or Automatic Location Identification(“ALI”) means a feature that provides the caller’s telephone number, address and the names of the Emergency Response agencies that are responsible for that address. ...
taken Hong Kong as their placeof permanent residencebefore or after the establishment of the HKSAR. legco.gov.hk legco.gov.hk 根據基本法第 24 條的規定,非㆗國籍㆟士如果在香港特別行政區成立以前或以後 持有效旅行證件進入香港、在香港通常居住連續七年以㆖並以香港為永久居住㆞,則可成為香港特別...
My generation was the last in American and perhaps even in world history for which this is true — the last undigitized generation, whose childhoods area’s up on the cloud but are mostly trapped in analog formats like handwritten diaries and Polaroids and VHS cassettes, tangible and imperfect...
Mui, MatthewYam, Alan