permanent establishment

Corporate Taxation (CT) Federal Decree No. 47 of 2022 (UAE CT Law) Federal Tax Authority (FTA) Ministry of Finance (MoF) OECD MC Convention (OECD MC) Permanent Establishment (PE) United Arab Emirates…

Corporate Taxation (CT) Federal Decree No. 47 of 2022 (UAE CT Law) Federal Tax Authority (FTA) Ministry of Finance (MoF) OECD MC Convention (OECD MC) Permanent Establishment (PE) United Arab Emirates…

Two cases, currently before different courts highlight long-standing questions around the attribution of profits to permanent establishments. Irish and United Kingdom law on the attribution of…

Despite tremendous efforts from OECD/G20 to keep the domestication of BEPS outcomes as smoothly as possible, the current international tax scenario is a rough, somehow agitated transition aimed at…

When UK voters went to the polls on 23 June 2016 and voted by a slim majority to leave the European Union, few of them had in mind the impact on taxation.  Future generations are unlikely to view it…

In highly dramatic fashion the French tax authorities and IT specialists raided Google's headquarters and McDonalds. I don't own Google stock. I'm not in favor of Google's near monopoly on search …

Model tax treaties do matter. The OECD and UN Models constitute precedent books with standard clauses that contracting states can follow or adapt to suit their particular circumstances. The US Model…

Interest and penalty regimes place a high premium on correctly identifying the existence of a permanent establishment in the territory of a state. The failure to do so often means that there is no…

In many respects a multilateral tax treaty represents an utopian view of international tax law: a wide consensus among nation states to submit themselves to a common set of rules that govern the…