Autor: Raphael Holzinger

Attribution of Participations to Permanent Establishments (II)

Petruzzi/HolzingerTPI 2018, 165

This article is the second of a two-part contribution that takes a detailed look at the attribution of participations to permanent establishments (PEs). It particularly addresses the tax consequences of attribution or non-attribution of participations to PEs, respectively, and gives an outlook on crucial aspects in practice.