The permanent establishment concept under tax treaties and its implications for multinational companies

Nakayama, Aiko (2012) The permanent establishment concept under tax treaties and its implications for multinational companies. Masters thesis, Institute of Advanced Legal Studies, School of Advanced Study.
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This dissertation explores the concept and implementations in practice of permanent establishment(PE) introduced by Article 5 in the OECD Model Income Tax Treaty, highlighting the implications and ambiguities for multinational companies and nation state tax regimes.


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