Permanent establishment rules for insurance enterprises: notification and consultation required before treaty inclusion between contracting states. The Protocol clarifies that no special deeming rule currently treats an insurance enterprise as having a permanent establishment merely by collecting premiums or insuring risks except through an independent agent; should Estonia later include such a provision in any treaty it will notify the other Contracting State and, after consultations between competent authorities, that provision may be considered for this Agreement. It also confirms that gains from alienation of immovable property situated in a Contracting State may be taxed in that State in accordance with Article 13.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Permanent establishment rules for insurance enterprises: notification and consultation required before treaty inclusion between contracting states.
The Protocol clarifies that no special deeming rule currently treats an insurance enterprise as having a permanent establishment merely by collecting premiums or insuring risks except through an independent agent; should Estonia later include such a provision in any treaty it will notify the other Contracting State and, after consultations between competent authorities, that provision may be considered for this Agreement. It also confirms that gains from alienation of immovable property situated in a Contracting State may be taxed in that State in accordance with Article 13.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
