permanent establishment

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The Indian Supreme Court has again expressed its views on the meaning of PE in the context of franchise arrangements for the operation of hotels in India under a well known brand. It also reflects a…

Jonathan Schwarz (Temple Tax Chambers; King’s College London) for OECD Commetary, permanent establishment, treaty interpretation

The Luxembourg High Administrative Court has rejected an appeal against a first instance decision that a holding company resident in Luxembourg had no permanent establishment in Malaysia within…