The Concept of Permanent Establishment in the Courts: Operating Structures Utilizing Commission Subsidiaries

Journal
Carmona Fernández, N.
International; Spain
Bulletin for International Taxation 2013 (Volume 67), No. 6
PriceUSD 45

This article examines the concept of a permanent establishment (PE) in several recent court decisions by analysing the weakness and inefficiency of a literal interpretation of the traditional PE concept, considering the scope of a commission agent and addressing the possibility of a wider concept of a PE.