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Business profits and permanent establishments presentation

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 presentation 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
Andrew MILLS
Andrew Mills FTIA (Life) is Managing Director of tax specialist firm Greenwoods & Freehills Pty Limited where he advises clients on a range of domestic and international tax issues, primarily in the financial services sector. His career spans over 25 years and includes periods in the Australian Taxation Office, as well as corporate and professional services organisations. Andrew was President of the Taxation Institute of Australia for 2006/2007 and is also a part time lecturer in the Masters of Law course at the University of Sydney in taxation. He is the Taxation Institute’s representative on Treasury’s Tax Treaties Advisory Panel and has spoken and written on international tax issues in a number of forums.
Current at April 2009
Click here to expand/collapse more articles by Andrew MILLS.
 

This was presented at International Tax Masterclass .

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