Focuses on the taxation of global business process outsourcing profits attributable to a permanent establishment in India. Routine of auditing the global books and records of the foreign enterprises; Concern over the prospect of international tax disputes; Terms excluded from the permanent establishment...
11, note 9 with further references;Skaar, Permanent Establishment—Erosion of a Tax Treaty Principle, 76;Sokolov, in: Brugger/Plansky (Eds.), Permanent Establishments in International and EU Tax Law, 13 (15).
July 12, 2024 Effective July 16, 2024, Nepal expanded the definition of permanent establishment to include nonresidents that have a significant digital presence in Nepal, which has yet to be further defined. 51 In March 2022, a bill was presented to the Lower House of the Parliament ...
The India-Singapore DTAA is a tax treaty signed between the government of India and the government of Singapore that stops residents of Singapore and India, who are taxpayers in their respective nations, from paying their domestic taxes twice on the same income. Initially introduced in 1994, the...
To ensure an individual enjoys tax treaty exemption, in addition to the presence of the individual as mentioned earlier, his remuneration has to be paid by, or on behalf of, an employer who is not a resident of Malaysia and the remuneration is not borne by a permanent establishment or ...
● Provisions for severance allowance and payments of severance allowance in excess of the prescribed amount per the Labour Code; ● Overhead expenses allocated to a permanent establishment ("PE") in Viet Nam by the foreign company's head office exceeding the amount under a prescribed revenue-ba...
Defining a permanent establishment (PE) is an important feature within all DTA treaties in order to determine the treatment of business profits. The PE refers to the fixed place of business through which the taxpayer carries out their business operations. ...
The term “central management and control” refers to the highest level of oversight, usually as exercised by the board, rather than day-to-day management. For example, if the board of a company is located in another country than where the firm has a permanent establishment (such as a ...
Since its establishment in 1992, the firm has grown into one of Asia’s most versatile full-service consultancies with operational offices across China, Hong Kong, India, Singapore and Vietnam as well as liaison offices in Italy and the United States....
by the All India Federation [...] daccess-ods.un.org 2009 年 12 月 19 日在全印度税务工作者联 盟于斋浦尔举行的“ 税务 政策 与经济发 展”全国税务会议上致开幕词。 daccess-ods.un.org [...] introduction of the new organizational structure of the National Taxation Department, in ord...