South Korea has proposed several key changes to its permanent establishment laws, including what triggers fixed-place and dependent-agent PE.
The Australian Tax Office issued a tax ruling confirming that an entity with central management and control in Australia may be considered an Australian tax resident.
Italy’s 2018 budget measures have changes that will affect multinationals operating in Italy and trading with Italian businesses.
On October 10, 2017, clarification regarding Peru’s tax amnesty regime was published.
Article 5 of the India-US Income Tax Treaty indicates that services provided in India will constitute a permanent establishment in India.
Officials from 76 countries met in Paris this month to sign or promise to sign an OECD multilateral convention that some describe as “a kind of super tax treaty.” This post describes what the convention is and why the signing ceremony should be a wake-up call for businesses.
Permanent establishment is an important subject for any company operating or planning to operate in another country. We asked Tom Lickess, Radius’ director of international tax, to talk about the basics of permanent establishment and how related laws are changing in today’s connected economy.
A Swedish Court's recent permanent-establishment ruling against a German company reflects a trend of evolving and increasingly strict PE regulations around the world. This post explains why the case is important for multinationals everywhere and what they can do to protect themselves from PE-related risks.
On August 30, 2016, the European Commission found that Ireland granted illegal tax benefits to Apple Inc., and demanded that Apple repay €13 billion to Irish tax authorities. We provide a clear, concise summary of the situation and tell you what you need to consider in the wake of the ruling.
Companies of all sizes — not just behemoths like Google and Facebook — are under increased scrutiny from tax authorities. We are in a time when corporate tax laws around the globe are evolving at a quick pace, and this understandably leaves many corporations uneasy and looking for clarity. Let’s look at two scenarios involving how a multinational might be taxed by two sets of tax authorities on the same income. Equipped with this knowledge, you may be able to avoid these kinds of pitfalls, or at least be prepared for the possibility that they may arise.
As of recently, Tax Authorities are making the case that job descriptions posted on LinkedIn by employees can be admitted as evidence that the corporation has triggered a permanent establishment in the region.
New rules in effect July 1 2013