Examples of using Permanent establishment in English and their translations into Danish
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Colloquial
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Official
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Medicine
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Financial
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Ecclesiastic
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Official/political
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Computer
At the same time, the pace of legislative change(such as the increasing enforcement of permanent establishment) is actually speeding up. Countries are using this type of legislation to increase overall levels of tax revenue.
That definition of a permanent establishment as an autonomous fiscal entity is consonant with international legal practice as reflected in the model tax convention drawn up by the Organisation for Economic Cooperation
Removing obstacles to cross-border services: The"mutual evaluation" provided particular evidence of difficulties in the cross-border provision of services without permanent establishment where the service provider is not permanently based in the country he/she is offering the service.
L. RonHubbard moved all operations and saw to the permanent establishment for the headquarters of the Hubbard Association of Scientologists in Phoenix, Arizona.
her country of residence unless the income in question can be linked to a'permanent establishment' in another country.
the existence of a permanent establishment certified by the tax authority of the Member State in which the receiving company is resident for tax purposes or in which the permanent establishment is situated;
The tax treatment of a permanent establishment which an SE resident for tax purposes in one Member State maintains in another Member State shall not result in a greater charge to tax for that permanent establishment than would arise in the case of a company which carries on a business of the same nature and is resident for tax purposes in that other State.
It is also contrary to those provisions for a Member State to allow a currency loss to be deducted as operating expenditure in respect of an undertaking with a registered office in a Member State only in so far as its permanent establishment in another Member State does not make any taxfree profits.
of startup capital granted to Deutsche Shell's permanent establishment in another Member State.
in the Member State where its permanent establishment is situated.
or the company whose permanent establishment is treated as the payer, of interest or royalties is an associated company of the company which is the beneficial owner, or whose permanent establishment is treated as the beneficial owner, of that interest or those royalties.
The profits repatriated to Germany from the permanent establishment were deducted from the‘startup capital' in amounts calculated on the basis of the exchange rate for the German mark(DEM)
the receiving company or permanent establishment shall be entitled on expiry of the year in question to interest on the tax which is refunded at a rate corresponding to the national interest rate to be applied in comparable cases under the domestic law of the source State.
Provision is made for deductible losses to be reincorporated automatically in cases where:- reincorporation has not occurred by the end of the fifth year following that during which the loss became deductible;- the permanent establishment or subsidiary is sold, wound up or transformed into a subsidiary or permanent establishment;- the undertaking's holding in the capital of the subsidiary falls below the minimum level laid down.
whether it is also contrary to Article 52 in conjunction with Article 58 of the Treaty if the currency loss concerned is deductible as operating expenditure of an undertaking with its registered office in a Member State only in so far as its permanent establishment in another Member State has not obtained any taxfree profits.
The answer to the second question must therefore be that it is also contrary to Article 52 in conjunction with Article 58 of the Treaty for a Member State to allow a currency loss to be deducted as operating expenditure in respect of an undertaking with a registered office in a Member State only in so far as its permanent establishment in another Member State does not make any taxfree profits.
also all those types of permanent establishment which are listed in the second subparagraph, point(a), of the first paragraph of Article 2, in a manner which distinguishes them from other categories of entity listed in the second subparagraph, point(b), of that article, which are excluded from the definition of permanent establishment under the Convention.
of the negative results of a permanent establishment situated in another Member State which belongs to a company with a registered office in the first State solely because those negative results are not capable of being taken into account for tax purposes in the Member State where the permanent establishment is situated.
Interest payments made on debt-claims issued by debtors who are residents of Switzerland or pertaining to permanent establishments of non-residents located in Switzerland shall be excluded from the retention.
List of the taxes to which undertakings, permanent establishments and subsidiaries must be subject in order to come under the provisions of the Directive. 4.