Concept under which a permanent
establishment is taxed by the country in which it is located not only on the
income and property, but also on all income derived by its foreign head office
from source in, and all property owned by the foreign head office situated in,
the country where the permanent establishment is located. The OECD model treaty
does not allow application of it.
Showing posts with label Force of attraction. Show all posts
Showing posts with label Force of attraction. Show all posts
Force of attraction
Concept under which a permanent
establishment is taxed by the country in which it is located not only on the
income and property, but also on all income derived by its foreign head office
from source in, and all property owned by the foreign head office situated in,
the country where the permanent establishment is located. The OECD model treaty
does not allow application of it.
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