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Analysing Article 7
Analysing Article 7

Analysing Article 7

Impact on PEs in Nine Major Trading Nations - Special Report


62 Pages, 8.75 x 12

Trade Paper, $135.00 (CA $182.00) (US $135.00)

Publication Date: September 2007

ISBN 9780906524411

Rights: US & CA

Spiramus Press (Sep 2007)

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This special report, based upon R.K. Rawal's comprehensive guide The Taxation of Permanent Establishments: An International Perspective, focuses on the different approaches taken in major international economies when implementing Article 7 on the avoidance of double taxation. The topics covered are: the taxation of profits of Permanent Establishments (PE) in the country of residence, transactions between the head office and PE, treatment of PE expenses, apportionment of profits, intra-group purchasing, income from immoveable property, and defining business profits. The countries covered include India, China, US, France, Germany, Italy, the Netherlands, Spain, and the UK.