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Is there a permanent establishment?
This report discusses the tax treaty definition of permanent establishment (PE). The included reports presents a global picture of how the short treaty definition of PE, and the most common extensions and exceptions to this definition, have been interpreted by courts and tax administrations.
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Advance rulings =, Cahiers de droit fiscal international Vol. 91b 2006 and Cahiers de droit fiscal international Volume 91a (The Tax Consequences of Restructuring of Indebtedness(debt work outs)).
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