UK & Offshore Tax Planning Blog
In many cases, a source country would treat a fixed place of business or a PE as a taxable source of income. Most double treaties include a business profits article which generally provides that business profits are only taxed in a jurisdiction where…
DSTs in one form or another have been unilaterally enacted by around 15 jurisdictions, including Austria, France, Spain, Kenya, the UK, Italy, India, Tunisia and Turkey. There are some big differences among DSTs that have been enacted or proposed, in…
Two key general principles of the current international tax system are that: Firstrly, foreign companies don't become subject to a country’s corporate income tax until they have created a permanent establishment (PE) there; and Secondly, income…