Requirements for assuming a permanent establishment under Art. 5 OECD Model Tax Convention
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چکیده
منابع مشابه
Attribution of Profit to a Permanent Establishment Involved in Electronic Commerce Transactions a Discussion Paper from the Technical Advisory Group on Monitoring the Application of Existing Treaty Norms for the Taxation of Business Profits
3 Foreword 1. To date, much attention has been focused on the question of in what circumstances do electronic commerce activities, especially the operation of a server in a particular jurisdiction, lead to the recognition of the existence of permanent establishment in that jurisdiction (the threshold question) under Article 5 of the OECD Model Tax Convention. Indeed, the Committee on Fiscal Aff...
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ژورنال
عنوان ژورنال: SCENTIA International Economic Review
سال: 2021
ISSN: 2748-0089
DOI: 10.52514/sier.v1i1.8