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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 Computerized.
[ 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 establishment' ...
[ 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, royalties ...
[ 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 establishment.
[ 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 leisure ...
[ 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 income.
[ 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 of.
[ 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 fixed.
[ 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 purpose ...
[ 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 treaty).
[ 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 business.
[ 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

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