Permanent establishment profit attribution limited to remuneration for actual activities, not total contract value under the tax treaty protocol. Profit attribution for permanent establishments under Article 7 is limited to remuneration attributable to the actual activities undertaken by the ... Summary
Permanent establishment profit attribution limited to remuneration for actual activities, not total contract value under the tax treaty protocol.
Profit attribution for permanent establishments under Article 7 is limited to remuneration attributable to the actual activities undertaken by the permanent establishment in the host Contracting State, rather than the enterprise's total receipts. In contracts for survey, supply, installation, construction or public works, the taxable profit of the permanent establishment is measured only by the part of the contract effectively carried out by that permanent establishment in the host State.
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