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Business profits and permanent establishments paper

Published on 18 Sep 08

This is an area where there is constant movement on multiple fronts all of which needs to be kept on the radar. This paper covers:

  • Australian developments
    • Tasman Group Services
    • recent private rulings on the existence of a permanent establishment
  • overseas developments
    • Knights of Columbus (Canada)
    • Morgan Stanley
    • DET Satellite
  • OECD developments
    • revised commentary to Article 7 of the OECD Model Treaty
    • revised commentary on profit attribution to permanent establishments.

Author profile

Andrew Mills CTA-Life
Photo of author, Andrew MILLS Andrew Mills, CTA (Life), is the Director, Tax Policy and Technical at the Tax Institute, a Senior Fellow at Melbourne University Law School and a member of the Tax and Transfer Policy Institute Advisory Board. Previously, Andrew was the Second Commissioner, Law Design & Practice, at the Australian Taxation Office from 2013 - 2019. Andrew has 40 years’ experience in taxation, including periods in the ATO, commerce and the tax profession. Andrew was a Director at Greenwoods & Freehills for more than 20 years and managing director of the firm from 2006 to 2011. Andrew was President of The Tax Institute in 2006–2007 and is a former Governor of the Taxation Research Foundation. In practice, Andrew was an active participant and representative of a number of industry bodies and a lecturer in the taxation in the Masters program at Sydney Law School. Andrew holds a Bachelor of Business, a Master of Laws and a Graduate Diploma in Tax Law. Andrew is a Chartered Taxation Adviser (Life), a member of the Australian Executive Committee of the International Fiscal Association and a graduate of the Australian Institute of Company Directors. - Current at 13 July 2020
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This was presented at International Tax Masterclass .

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Sharp edges in a modular world

Author(s):  Ian STANLEY

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