About Product
This book is Comprehensive Commentary on Law relating to Permanent Establishment presented in a lucid manner, along-with consolidated precedents and practices followed by 30+ countries worldwide. The Present Publication, authored by Ashish Karundia, is the latest edition, with the following noteworthy features: The book thoroughly discusses practical implication of various types of Permanent Establishments, including but not limited to the following: o Fixed Place Permanent Establishment [Article 5(1)] o Construction Permanent Establishment [Article 5(3)] o Service Permanent Establishment [Article 5(3)] o Agency Permanent Establishment [Article 5(5)] o Relationship between Article 5(1) & Article 5(2) has also been discussed In-depth analysis of 400+ judicial and administrative decisions from 33 countries, with emphasis on Austria, France, Germany, India, Netherlands, Spain and United States of America. Drawing on Case Law, administrative practice, and business decisions in numerous jurisdictions, the book discusses the permanent establishment criteria under conditions of e-commerce and the service economy. The book examines the in-depth and practical implication of various issues including: o Tangible vs. Intangible place of business in prevailing e-commerce scenario o Time duration where outsourcing or sub-contracting is done o Man days vs. Solar days o Disposal right over the place of business o Core business activity vs. Auxiliary or preparatory activity o Connection between place of business and carrying of business o Start and end of permanent establishment o Multiple permanent establishments o Construction permanent establishments: Deeming diction or exception to Article 5(1) o Supervision activity and sub-contracting o Secondment of employees o Stewardship or shareholder activity o Status of the agent in the source country o The differences between civil law and common law concepts of representations o Authority to conclude contracts vs. Maintenance of stock vs. Securing of order
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