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.
India’s top court ruled that UK-based Formula One’s three-day race in India constitutes a permanent establishment. The ruling is more evidence that PE laws are changing as countries rethink tax collection in an evolving global economy. This post gives brief summaries of recent rulings and tips for avoiding trouble in the new climate.
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.
There are a number of international tax issues that affect providers and purchasers of cloud computing software, including characterizing software payments. Characterization affects how software receipts are taxed and whether withholding tax should be applied. In short, software-payment classification can have a big impact on the overall profitability of a sale and the cash flows associated with it.
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.
Influential global bodies like the Organization for Economic Cooperation and Development (OECD) have targeted perceived multinational corporate tax avoidance through programs like the Base Erosion and Profit Shifting (BEPS) project. At a basic level, these and related country-specific initiatives target the perceived avoidance of permanent establishment (PE) and egregious transfer pricing practices. What has changed and how does this impact your business operations?
Last week’s webinar Know Before You Go: International Expansion and Permanent Establishment Risk encouraged a lot of discussion.There were several interesting questions from attendees for HSP's permanent establishment expert Justin Smith; here are some of the highlights, and answers.