Taxmann’s Permanent Establishment Emerging Trends by The Chamber of Tax Consultants – 1st Edition November 2020.

Taxmann’s Permanent Establishment Emerging Trends by The Chamber of Tax Consultants – 1st Edition November 2020.

Description

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

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