This online database is the only per-country study of the role of permanent establishments in international tax law and their impact on international business.

Gives a practical insight in all aspects of permanent establishments.

• Common-format country chapters enable rapid and accurate comparison and cross-referencing of information between countries.
• Frequent updates.
• E-mail notification as soon as new changes are available.

At the end of this year the country chapters of Permanent Establishments will be available in a new format.

[PDF] View the new format

[PDF] View the current format

Section 1

• Detailed commentaries on Articles of the OECD Model Tax Convention.
• Commentary on Article 5 (Permanent Establishments) by Dr Arvid A. Skaar.
• Commentary on Article 7 (Business Profits) by Dr Irene J.J. Burgers.
• Detailed study by Dr Otmar Thömmes and Klaus Eicker of the EC law aspects of permanent establishments.

Section 2

• Introduction, describing and contrasting resident and non-resident tax liability.
• Definition of a permanent establishment, including its interpretation in national law and tax treaties.
• Organization of a permanent establishment, including details of the practical aspects of setting-up a permanent establishment.
• Determination of the taxable income of a permanent establishment, including methods for the avoidance of double taxation and the possibility for a set-off of losses; divided into "domestic" and "foreign" permanent establishments.
• Other issues.

The Editors

• Dr Irene J.J. Burgers
  University of Groningen
• Anuschka Bakker
  IBFD, Amsterdam

Argentina, Australia, Belgium, Brazil, Canada, Estonia, France, Germany, Hungary, Ireland, Italy, Japan, Mexico, Netherlands, Poland, Portugal, South Africa, Spain, Switzerland, United Kingdom, United States, Uruguay