Permanent Establishment Implications for Coordination Centres in the Oil and Gas Industry
Journal
Country
International; OECD
Published Date
Issue
Bulletin for International Taxation 2013 (Volume 67), No. 9
Document
This article analyses the permanent establishment (PE) concept in relation to a coordination centre of a non-resident company in the oil and gas industry, considering whether the coordination centre constitutes a basic rule PE and whether it should be aggregated with the company’s other places of business in a foreign jurisdiction.