International - Business Restructuring and Permanent Establishments
- J.L. Cooper; S.B. Law
- International Transfer Pricing Journal, 2010 (Volume 17), No 4
- 9 June 2010
This article outlines two common forms of business restructuring involving the conversion of manufacturing and distribution entities; and, by way of analysis of the permanent establishment articles in bilateral treaties that entered into force between 1 January 2008 and 31 December 2009, considers permanent establishment risks associated therewith.