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.