Model Tax Convention: Attribution of Income to Permanent Establishments
收藏Organisation for Economic Co-operation and Development2026-04-11 收录
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https://www.oecd.org/en/publications/model-tax-convention-attribution-of-income-to-permanent-establishments_g2ghgc21-en.html
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This publication examines the circumstances under which income is to be attributed to a permanent establishment for purposes of an income tax treaty, particularly where goods, services, or intangibles are transferred between the permanent establishment and the home office or another permanent establishment in a third country.
