常设机构 )受控外国公司(permanent establishment)Tax becomes an increasingly important component in China's economy with China's development of export-oriented economy. An accurate vocabulary translation is the basis of sentence and text translation. This paper aims to discuss characteristics of tax ...
Foreign residents with Construction Projects in Australia should carefully consider whether such disruptions may unintentionally be creating Australian “permanent establishment” (PE) issues (including obligations to lodge income tax returns in Australia, determine...
How to open a permanent establishment in Italy Tax obligations for permanent establishments in Italy Get started with Stripe Foreign businesses that want to operate in Italy have multiple options: they can set up a local business unit (such as a representative office), establish a branch or...
The Situation:In December 2020, the French administrative supreme court issued a major decision expanding the permanent establishment ("PE") concept and criteria for both French corporate income tax ("CIT") and value-added tax ("VAT") purposes. The Result:A PE may exist in France if an agen...
” This issue of China Briefing Magazine casts some light on permanent establishment status in China by discussing the circumstances triggering a PE in China, focusing on Service PEs. We also discuss the tax implications for a non-resident enterprise where its activities in China constitute a ...
The term “permanent establishment” (“PE”) is used in tax to convey the connection of a business to a country. Generally, this connection provides a country the right to tax the income earned in or allocated to the country, triggering filing requirements and tax obligation. Whilst tax rule...
tax authorities as to whether its activities in relation to the parent company could trigger a PE related to a fixed place, dependent agent and/or the provision of services. Keep in mind as well that the corporate group could have additional permanent establishment risks in the country ...
BEPS Action 7 consideration: UK personnel or overseas personnel present in the UK should limit UK activity to promotion and advertising and this will ensure that a permanent establishment is not created. Staff members in the UK conducting key activities ...
Cf.Skaar, Permanent Establishment—Erosion of a Tax Treaty Principle, 76. 7. DE: Stehendes Gewerbe. 8. Cf.Skaar, Permanent Establishment—Erosion of a Tax Treaty Principle, 76 et seq.; alsoKroppen, IWB 2005, 727 (728). 9. German Double Taxation Act, 22 Mar. 1909, RGBl. 1909, 332....
1)permanent establishment常设机构 1.E-commerce has made impact on the conventional international tax system in the following aspects:permanent establishment concept,criteria of residential identity,classification of the quality of income.电子商务对传统的国际税收规则造成了冲击:常设机构原则、居民身份的认定标...