Abstract
This article is the second of a two-part contribution that takes a detailed look at the attribution of participations to permanent establishments (PEs). It particularly addresses the tax consequences of attribution or non-attribution of participations to PEs, respectively, and gives an outlook on crucial aspects in practice.
Original language | English |
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Pages (from-to) | 165 - 175 |
Journal | Transfer Pricing International (TPI) |
Issue number | 3 |
Publication status | Published - 2018 |
Austrian Classification of Fields of Science and Technology (ÖFOS)
- 505004 Financial law