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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 has overall responsibility for the ATO’s law practice, including law interpretation, dispute resolution and the ATO’s role in policy and law design. Andrew has more than 30 years of 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, is a former Governor of the Taxation Research Foundation and also represented industry bodies across a number of sectors. Andrew holds a Bachelor of Business, a Master of Laws and a Graduate Diploma in Tax Law. He is a Chartered Taxation Adviser (Life) of The Tax Institute, a member of the International Fiscal Association and a graduate of the Australian Institute of Company Directors. - Current at 29 November 2017
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This was presented at International Tax Masterclass .

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