Problems With Permanent Establishments - TTN Transnational ...
Problems With Permanent Establishments - TTN Transnational ...
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Services PE<br />
–Why?<br />
• Source State’s taxing rights<br />
• Similar treatment of business activities<br />
– A Broad Concept?<br />
• Flexibility in deeming a PE to exist<br />
– Article 14 OECD MC?<br />
• Independent personal services<br />
Faculty of Law – Department of Tax Law
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