Description
Taxmann Publications Permanent Establishment Emerging Trends by Taxmann
The study of Permanent Establishment has emerged as intriguing and complex subject. This book serves as a complete guide for resolution of complexities involved in the concept of permanent establishment.
The structure of the book is as follows:
· This book opens up with ‘adaptation of Indian domestic tax laws’ to the ‘global trend’
· The advent of ‘Significant Economic Presence’ and its ramification on the changing concept on business connection has been deliberated in this book
· Evolution of permanent establishment (‘PE’) in the e-world
· Insights into Multilateral Conventions (‘MLI’) & OECDs position on the changing garb of PE
· The book closes with the impact of changing philosophy of PE in the international tax space & in the domestic tax legislature.
The contents of the book are as follows:
· Introduction
· Territorial nexus becomes aerial
· Adaptation of Indian Domestic Laws
· PE in digital economy
· PE under Data Localisation Regime
· Server as PE
· Modification in Agency PE definition
· Modification in Independent agent definition
· Preparatory or auxiliary activities
· Construction PE – Journey, Abuse and Remedy
· Conclusion
· Annexures
o Relevant Provisions of the Act
o OECD Model Convention (Relevant extract)
o PE Articles under various treaties
o Relevant Articles of Multilateral Conventions
o MLI Impact on PE Article of treaties extracted in Part III