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A Comprehensive Commentary on Law relating to Permanent Establishment as defined in Art. 5 of the OECD 2010 Model Convention, the UN 2011 Model Convention and various bilateral tax treaties. An in-depth analysis of almost all leading court decisions, advance rulings and administrative rulings in various countries including India, the United States, Germany, the Netherlands, Belgium, Norway, Switzerland, Spain, Canada, New Zealand, South Africa, Russia, Luxembourg, Italy, Austria and Greece. The book thoroughly discusses practical implications of various types of Permanent Establishments, including: Fixed place Permanent Establishment [Art. 5(1) of model conventions and various bilateral tax treaties]; Permanent Establishment illustrations [Art. 5(2)]; Construction Permanent Establishment [Art. 5(3)] [Art. 5(2) in certain bilateral tax treaties]; Service Permanent Establishment [Art. 5(3)] [Art. 5(2) in certain bilateral tax treaties]; Permanent Establishment - Exclusion Provisions [Art. 5(4)]; Dependent agency Permanent Establishment [Art. 5(5)] and independent agents [Art. 5(6)]; and Permanent Establishment implications in case of subsidiary/group entities [Art. 5(7) of the OECD 2010 Model Convention, Art. 5(8) of the UN 2011 Model Convention and various bilateral tax treaties].
- Sales Rank: #2197046 in eBooks
- Published on: 2012-06-04
- Released on: 2013-04-17
- Format: Kindle eBook
About the Author
Dr. Amar Mehta is a Chartered Accountant -India- with about 20 years of professional experience. He specializes in International Taxation with focus on client Business Transaction in with India. He is a former partner at Ernst & Young in India and a former Senior Manager at Ernst & Young in Toronto. He has advised numerous companies from North America, Europe and the Asia Pacific on international business transactions in India including setting up foreign joint-ventures, subsidiaries, mergers and acquisitions, infrastructure and hospitality projects and other financial transactions of diverse nature. Amar is a member of the Institute of Chartered Accountants of India. He holds a Bachelor of Commerce Degree from University of Mumbai, Post-Graduate diploma in tax management from the Institute of Chartered Accountants of India, a Master s degree from an American law school and Ph.D. in international taxation from University of Amsterdam, the Netherlands.
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