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Permanet Establishment and Transfer Pricing: Two Sides of the Same Coin

01/01/2005

Does a subsidiary constitute a permanet establishment of its foreign parent company where the relevant treaty requirements are met, that is, either represents a fixed place of business or it is dependent on, and has the power to contractually bind in its country of establishment, the foreign parent company?

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Publication
Tranfsre pricing and PE Article Tax Planning Int 2005
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Portrait ofGiovanni Cali
Giovanni Cali
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Rome