Title: |
A Research on Permanent Establishment:Definition and Judicial Applications |
Source: |
International Conference on Engineering and Business Management 2012(Part 2 Enterprise Operation and Management(2))
(pp 1408-1410)
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Author(s): |
Changda Cai, Department of Public Economics, Xiamen University, Xiamen, China, 361005 |
Abstract: |
This paper begins with a brief introduction of the much discussed question about Permanent Establishment (PE). Based on OECD Model Tax Convention, the definition of PE can be divided into five parts.For each part, an in-depth analysis will be given, with examples or jurisdictions in some countries. Then this paper continues with some common extensive issues concerning PE definition as well as corresponding judicial applications in various countries. Finally, a summary and conclusions on understanding PE will be made.
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