permanent establishment definition

permanent establishment means a fixed place of business through which the business of an enterprise is wholly or partly carried on.
permanent establishment means a fixed place where a business is wholly or partly carried on including —
permanent establishment means a fixed place of business situated in a Member State through which the business of a company of another Member State is wholly or partly carried on in so far as the profits of that place of business are subject to tax in the Member State in which it is situated by virtue of the relevant bilateral tax treaty or, in the absence of such a treaty, by virtue of national law.

Examples of permanent establishment in a sentence

  • For further information, refer to Example No. 6 of GST/HST Policy Statement P-208R, Meaning of Permanent Establishment in Subsection 123(1) of the Excise Tax Act (the Act).

  • From and after the Closing until the creation of a Permanent Establishment, (i) such Employees shall remain employees of Sellers but shall be seconded to Buyer on a full-time basis pursuant to a secondment agreement reasonably acceptable to Buyer and Sellers to be entered into promptly following the Closing.

  • No Permanent Establishment - Company does not have a permanent establishment (within the meaning of an applicable Tax treaty) nor otherwise have an office or fixed place of business in a country other than the country in which it is organized.

  • Permanent Establishment in Canada......................73 ARTICLE IV Conditions...................................................74 SECTION 4.01.

  • This FIRST AMENDMENT TO MANAGEMENT SERVICES AGREEMENT, is made as of January 1, 2003 (this “Amendment”), between SBC INTERNATIONAL MANAGEMENT SERVICES, INC., a corporation duly organized under the laws of the State of Delaware, United States of America, with headquarters in Wilmington, Delaware, USA, with Permanent Establishment in the United Mexican States under the Income Tax Law with address at Parque Xxx 000-00xx xxxxx, Xxxxxxx Xxxxxxxxxx 00000 Xxxxxx, X.


More Definitions of permanent establishment

permanent establishment shall include especially :
permanent establishment in relation to a person, means a 1[fixed] place of business through which the business of the person is wholly or partly carried on, and includes –
permanent establishment means a fixed place of business through which the business of a person is wholly or partly carried on, and includes the following:
permanent establishment means a permanent establishment as defined from time to time in Article 5 of the Model Tax Convention on Income and on Capital of the Organisation for Economic Co- operation and Development;
permanent establishment means any fixed base of business (xxxxxxx organizzazione) regulated by article 162 of Presidential Decree No. 917 of 22 December 1986, Article 5 of the Organization for Economic Cooperation and Development Model Tax Convention and or any equivalent provision provided for by any relevant legislation.
permanent establishment means a fixed place of business through which the business of the company is wholly or partly carried on;
permanent establishment when used with respect to an enterprise of one of the territories means a branch, depot, management, factory, farm, mine, quarry or other fixed place of business including any place of natural resources subject to exploitation and a place where construction work or the installation of plant or machinery is carried on but does not include an agency unless the agent has, and habitually exercises, a general authority to negotiate and conclude contracts on behalf of the enterprise or has a stock of merchandise from which he regularly fills orders on its behalf. In this connection -