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…
The services permanent establishment concept is perhaps the most noteworthy contribution to tax treaties provided by the UN model. The tax treaty concluded by South Africa and the United States in…
Article 7(1) of the OECD model treaty is perhaps the most important rule regulating the international taxation of business. It sets out the fundamental basis on which businesses are taxed, that is,…
