Permanent Establishments:A Planning Primer

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This book is a comprehensive review of the tax treaty concept of a “permanent establishment’ from its origins in early Prussian and British tax law to its present manifestation in over 1250 bilateral income tax treaties written by two of the leading authors on the subject. The book covers both Anglo Saxon and civil law precedent, The OECD and US model treaties used in developed country treaties and the differing approach of the UN model for developing countries. The book exhanstively deals with all aspects of the "fixed place of business’ and "dependent agency’ permanent establishments and the exceptions for independent agents, permitted ancilliary activities and parent subsidiary relationships. The text integrates conceptual analyses and technical discussion with relevant tax planning opportunities, appropriately highlighted or diagrammed. A number of valuable tax planning techniques are presented which have not been previously discussed in any literature.