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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:

Author Photo - Andrew Mills CTA-Life
Andrew Mills CTA-Life
Andrew commenced the role of Second Commissioner in March 2014. 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 over 30 years experience in taxation including periods in the ATO, commerce and the tax profession. Andrew was a Director of the specialist national tax firm, Greenwoods & Freehills for over 20 years and Managing Director of the firm from 2006 to 2011. Andrew was the 2006-2007 President of The Tax Institute, a Governor of the Taxation Research Foundation and also represented industry bodies across a number of sectors. Current at 18 May 2015 Click here to expand/collapse more articles by Andrew MILLS.

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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