Permanent Establishments and Force of Attraction: Some Implications of TD Securities, in General and from an Indian Perspective

Journal
Author
Chaturvedi, A.
Country
Canada; India; International
Published Date
Issue
Bulletin for International Taxation 2011 (Volume 65), No. 2
FormatPDF
EUR
45
| USD
50 (VAT excl.)

The author, in this article, examines the concept and the role of tax treaties, with specific regard to permanent establishments (PEs), force of attraction, and the implications of the Canadian TD Securities decision generally and from an Indian perspective. The author also considers the attribution of profits to a PE.