Dell Wins Important Agency Permanent Establishment Case

Journal
Bjerke, J.M.; Søgaard, S.S.
Norway
International Transfer Pricing Journal 2012 (Volume 19), No. 3
FormatPDF
EUR
45
| USD
50 (VAT excl.)

Dell recently won an important tax case before the Norwegian Supreme Court regarding the interpretation of the agency permanent establishment rule under the Norway–Ireland treaty. This article analyses the Court's decision, as well as those of lower courts, and considers the potential future impact of the Court's decision.