Permanent Establishments and Force of Attraction: Some Implications of TD Securities, in General and from an Indian Perspective

Journal
Chaturvedi, A.
Canada; India; International
Bulletin for International Taxation 2011 (Volume 65), No. 2
PriceUSD 45

The author, in this article, examines the concept and the role of tax treaties, with specific regard to permanent establishments (PEs), force of attraction, and the implications of the Canadian TD Securities decision generally and from an Indian perspective. The author also considers the attribution of profits to a PE.