South African Tax Court Departs from Commentary on Article 5 of the OECD Model in Finding a Permanent Establishment

Journal
Mazansky, E.
South Africa
Bulletin for International Taxation 2015 (Volume 69), No. 9
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In this article, the author considers a recent decision of the South African Tax Court, which might be considered controversial in some quarters, concerning whether or not a US company had a permanent establishment in South Africa.