permanent establishment - OECD
Oct 12, 2011 ... Article 5 (Permanent Establishment) of the OECD Model Tax ... treaty concept of
permanent establishment, which is primarily used for the purpose of the
allocation of taxing rights when an enterprise of one State derives business
profits from .... Can the premises of a (converted) local entity constitute a ...
[ 48836726.pdf - Read/Download File
Creation of a Permanent Establishment - IRS.gov
Sep 3, 2014 ... Permanent Establishment Concept in U.S. Income Tax Treaties: In general, U.S.
... will not be deemed to have a U.S. permanent establishment if its ... business
through both owned and franchised hotels. ... Canada and India). .... and Purpose
... elements that have been used in common law to indicate that ...
[ TRE9450_06_02.pdf - Read/Download File
22 April 2014 - PwC
Apr 22, 2014 ... has analysed the emergence of a Permanent Establishment (''PE'') for a foreign
company by ... used by its personnel when in India, notwithstanding the fact that
the location of the top ... respect of the business carried out by GPI. .... of such
personnel in India can be deemed to constitute a fixed place PE.
[ pwc_news_alert_22_april_2014_renoir_consulting_limited.pdf - Read/Download File
US Inbound Corner - Deloitte
Dec 31, 2014 ... Long-Term US Travel Hotel Tax – Potential Refund Opportunity. ... Permanent
Establishment and Secondment Agreements – Challenges of ..... taxpayers can
change the lifetime deduction of business expenses, .... deemed non-resident for
US gift and estate tax purposes are still subject to these taxes.
[ us_tax_usinboundcorner_141215.pdf - Read/Download File
Aiko Nakayama The permanent establishment concept under tax
(E) The definition of a permanent establishment in Japan, UK, India, ....
establishment can be deemed to exist only if the place of business has a ... some
right to use the premises for the purposes of its business and not solely for the
...... hotels and airlines pertaining to reservations and booking through its
[ Aiko_Nakayama_MA_Taxation_dissertation.pdf - Read/Download File
Permanent Establishment - APT & Co.
business connection in India is deemed as accruing or arising in India. • No
specific ... amount of spaces at its disposal which is used for business activities or
in ... at times can be considered as permanent establishment. ➢ Services like ...
Hotel rooms using for undertaking business activities would considered as a
place of ...
[ pe-avinash-gupta.pdf - Read/Download File
Doing Business in Oman A tax and legal guide - PwC
establishment or changing of businesses in the country. ... and used in business.
... if the activity is deemed by the Council of Ministers to be of ... office in Oman
solely for the purpose of marketing and .... Ensure the foreign company can
continue to comply with ... Under Oman tax law, a permanent establishment ('PE')
[ Doing-Business-Guide-Oman.pdf - Read/Download File
Permanent Establishments 2.0 - PwC
which can be identified on the topic of permanent establishments. .... The
permanent establishment risk is increased significantly by the inability of tax
departments to ensure that the business side .... sanctions is used more and
more as an effective ... principal was still deemed to have a ..... The purpose of
this survey was to.
[ pwc-permanent-establishments-at-the-heart-of-the-matter-final.pdf - Read/Download File
Tax & Regulatory Quarter - EY
Jun 1, 2013 ... While offering the salary income to tax in India, the Taxpayer .... M Far Hotels Ltd.
(Payer) [TS-133-ITAT-2013(Coch)], ruled that where the DTAA does not talk
about the surcharge ... be used wholly or partly for the purpose of business being
fulfilled ... Delhi Tribunal on permanent establishment and profit.
[ Tax_and_Regulatory_Quarter.pdf - Read/Download File
Doing Business in Jamaica - UHY International
A detailed firm profile for UHY's representation in Jamaica can be found in ...
shown, but inevitably they are both general and subject to change and should be
used for ... distinct personality has been flavoured by Taino, African, Indian,
Chinese, ...... Foreign companies which are deemed to have a 'permanent
[ Doing-Business-in-Jamaica.pdf - Read/Download File
Worldwide Tax Guide 2014 - PKF
A country's tax regime is always a key factor for any business considering moving
into ... available in PDF format which can be downloaded from the PKF website at
... The contents should not be used as a basis for action without further ......
permanent establishment in Algeria are subject to withholding tax of 24% on their
[ PKF Worldwide Tax Guide 2015.pdf - Read/Download File
India - Zambia - Zambia Revenue Authority
(a) He shall be deemed to be a resident of the Contracting State in which he has
a permanent ... For the purposes of this Convention, the term “permanent
establishment” .... enterprise and to income from immovable property used for the
performance of ... business; but does not include income in the form of rents,
[ India-Zambia Double Taxation Agreement.pdf - Read/Download File
Double Taxation Agreement between India and - ASEAN Briefing
Oct 16, 1981 ... establishment, business advisory, tax advisory and compliance, accounting, ...
which India has certain rights and to the extent these rights can be exercised
therein as if ... For the purpose of this Agreement, the term " resident of a ... shall
be deemed to be a permanent establishment of that enterprise in the ...
[ Asia_DTA_Tanzania_India.pdf - Read/Download File
Indonesia Tax Profile - KPMG
third parties, nor does KPMG International have any such authority to ... for tax
purposes if they have a permanent establishment (PE) in Indonesia. ... royalties),
unless the non-resident has a permanent establishment in .... Limited liability
companies are the typical legal entity used for conducting business in Indonesia.
[ indonesia-2015.pdf - Read/Download File
Netherlands - KPMG
Chapter 15 | India. 279. Chapter ... description of commonly used financing
structures in film and television, as .... income will be subject to Dutch personal
income tax (PIT) or CIT. .... then the non-resident limited partner is deemed to be
engaged in a trade or business in The Netherlands through a permanent
[ Film financing and television programming- the-netherlands.pdf - Read/Download File
A Tax Planning Primer for U.S.-Controlled Indian Business Operations
Feb 23, 2009 ... The purpose of this article is to provide the U.S. tax adviser with a .... party does
not have a permanent establishment in the other country.
[ Tax-Planning-Preimer-for-U-S-Controlled-Indian-Business-Operations-Sharp-Cortes-India-Feb-2009A.pdf - Read/Download File
Doing Business in Oman 2015 - Moore Stephens
In order to be aware of specific laws and regulations in more detail, it will be
necessary to ..... f) Permanent Establishments (PE) of Foreign Companies and
establishments .... interest paid on bank borrowings used for business purposes.
... Municipal tax is levied at 5% on hotel income, 3% on property rents, 10% on
[ Oman-DBI-2015.pdf?ext=.pdf - Read/Download File
Doing Business in Oman
Indian subcontinent and the Far East. .... The various types of entities under
which a business can be established and ..... business entity and used by it for
business purposes only if it continues to be in use ... having deemed permanent
establishment status are entitled to a deduction for .... 4% is charged on hotel
[ doing_business_in_Oman.pdf - Read/Download File
finance memorandum - NYC.gov
Aug 23, 2011 ... addition, it aims to clarify the permanent resident exclusion, and to ... similar
establishments that are regularly used and kept open for the lodging of
occupants. ... hotel for Hotel Tax purposes if rooms, apartments or units are
rented ... As explained below, room or rooms in a hotel does not include a place
[ fm3608htx.pdf - Read/Download File
Guide Book for Overseas Indians on Taxation and Other Important
to serve as a guide to them and does not purport to be a legal document. ...
Promote overseas Indian investment into India and facilitate business .... he shall
be deemed to be resident in ... income- tax purposes, an Indian citizen ..... same
foreign currency as was initially used in ..... such permanent establishment or
[ OIFCPublication2009GuidebookonTaxationforOI.pdf - Read/Download File
chapter 123 income tax act - Justice Services
Business of Insurance) Regulations, (in this proviso referred to as 'the ... and
purposes of the Income Tax Acts, every cell of a securitisation cell ... solely of
such a holding of share capital, but where it can be ... Act and attributable to a
permanent establishment .... article 14(1)(f) or (j), and which is first used for this
[ download-document-aspx-app-lom-itemid-8658.pdf - Read/Download File
The Corporate “Mixed Marriage” - American Bar Association
Feb 17, 2012 ... 'Carrying on business' does not mean the performance of a single ... used the
hotel as his address, had suppliers contact him ... of 'permanent establishment,'
even where not apparently ... India: e.g. Seagate Singapore (warehouse as. PE).
.... treaty benefits if PS is not the legal employer but is deemed the.
[ marriage.pdf - Read/Download File
India Budget 2016: Analysis of Tax Changes and Impact on Business
Mar 7, 2016 ... from NPS to the extent of 40% will be exempt from tax. ... be deemed to be closed
in case the assessee discharges the applicable dues. ➢ Annual ... to fully allow
CENVAT Credit on inputs/ input services used .... for specified services received
by a non-resident not having a Permanent Establishment in India.
[ india-budget-2016-roedl-partner.pdf - Read/Download File
International Business Taxation - Tax Justice Network
(b) Taxing the Profits of a Business Establishment: France. 10 ... (a) The Business
Purpose Rule .... Chapter 11 Global Business and International Fiscal Law .....
taxation at source to the business profits of a Permanent Establishment or .....
management' principle used in many tax treaties (based on the OECD model
[ Picciotto 1992 International Business Taxation.pdf - Read/Download File
Destination India 2015
A foreign entity looking to set up operations in India can consider ... (
Establishment of Branch or Office or Other Place of Business) ..... and
infrastructure and specified service sectors such as hotels, ... ECBs so raised can
be used for certain prescribed purposes ..... Is received or deemed to have been
received in India.
[ pwc_destination_india_2015.pdf - Read/Download File
Publication 848:(2/15):A Guide to Sales Tax for Hotel and Motel
This publication does not address any of the locally-imposed taxes on hotel
occupancy administered ..... similar establishments that are regularly used and
kept open for the ... deemed to operate a hotel, or a portion thereof, with respect
to which the ..... for purposes of determining permanent resident status apply to
[ pub848.pdf - Read/Download File
guidelines for taxation of international air transport profits - IATA
for peaceful purposes; c) Encourage ... materially from foreign business
enterprises which engage in manufacturing ... among airlines due to the
influence of IATA can justify the ... waters, consequently the full cost of operating
aircraft used ... permanent establishment as defined in most double taxation .....
Jet Lite (India) Ltd.
[ taxation_intl_air_transport profits_final.pdf - Read/Download File
India - Revenue
The Government of Ireland and the Government of the Republic of India, desiring
to conclude a .... RESIDENT. 1. For the purposes of this Convention, the term “
resident of a ... An enterprise shall be deemed to have a permanent
establishment in a .... The term “dividends” as used in this Article includes income
from shares or ...
[ india.pdf - Read/Download File