Permanent Establishment Emerging Trends

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 Present Publications is the Latest Edition, authored by The Chamber of Tax Consultants. 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
    • Relevant Provisions of the Act
    • OECD Model Convention (Relevant extract)
    • PE Articles under various treaties
    • Relevant Articles of Multilateral Conventions
    • MLI Impact on PE Article of treaties extracted in Part III