Permanent establishment (English Wikipedia)

Analysis of information sources in references of the Wikipedia article "Permanent establishment" in English language version.

refsWebsite

Global rank English rank

13doi.org

2^nd place

10oecd-ilibrary.org

6,201^st place

5,692^nd place

3oecd.org

960^th place

854^th place

2un.org

97^th place

164^th place

1sites.google.com

626^th place

690^th place

1ey.com

6,295^th place

4,898^th place

1ustreas.gov

low place

1web.archive.org

1^st place

1info.gov.za

low place

8,235^th place

1fin.gc.ca

low place

1irs.gov

3,125^th place

1,832^nd place

doi.org

Kobetsky, Michael (2011). "History of tax treaties and the permanent establishment concept". International Taxation of Permanent Establishments. pp. 106–151. doi:10.1017/cbo9780511977855.005. ISBN 9780511977855.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2015). OECD/G20 Base Erosion and Profit Shifting Project, Addressing the Tax Challenges of the Digital Economy, Action 1 - 2015 Final Report. OECD/G20 Base Erosion and Profit Shifting Project. doi:10.1787/9789264241046-en. ISBN 9789264241022.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Article 5 and Commentary. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Commentary 5-6 to Article 5. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Commentary 4 to Article 5. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Commentary 7 to Article 5. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Commentary 12 to Article 5. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155. This paragraph contains a list, by no means exhaustive, of examples, each of which can be regarded, prima facie, as constituting a PE. As these examples are to be seen against the background of the general definition given in paragraph 1, it is assumed that the Contracting States interpret the terms listed, a "place of management," a "branch," an "office" etc in such a way that such places of business constitute a PE only if they meet the requirements of paragraph 1.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version, Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Article 4 and Commentary thereon. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Paragraph 5 of Article 5 and Commentary 31 to Article 5. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Paragraph 7 of Article 5 and Commentary 40-41 to Article 5. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Paragraph 6 to Article 5 and Commentary 36-39. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2015). OECD/G20 Base Erosion and Profit Shifting Project, Developing a Multilateral Instrument to Modify Bilateral Tax Treaties, Action 15 - 2015 Final Report. OECD/G20 Base Erosion and Profit Shifting Project. doi:10.1787/9789264241688-en. ISBN 9789264241671.

ey.com

"Saudi Arabian tax authorities introduce Virtual Service PE concept". www.ey.com. Retrieved 2016-03-15.

fin.gc.ca

For example, the Canada/Belgium treaty sets this limit as 12 months, as does the OECD Model. By contrast, the US/India treaty treats such a site, project or activities continuing for more than 120 days in any twelve-month period as a PE.

info.gov.za

See, e.g., the U.S./UK treaty Archived 2010-05-27 at the Wayback Machine Article 5, which is virtually identical to the OECD Model Article 5. The Nigeria/South Africa treaty Archived 2011-06-29 at the Wayback Machine Article 5, is nearly identical to the OECD Model Article 5, with the addition of a provision clarifying that a fixed place of business used as a sales outlet is a PE, notwithstanding exclusions elsewhere in the article.

irs.gov

For example, the Canada/Belgium treaty sets this limit as 12 months, as does the OECD Model. By contrast, the US/India treaty treats such a site, project or activities continuing for more than 120 days in any twelve-month period as a PE.

oecd-ilibrary.org

OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Article 5 and Commentary. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Commentary 5-6 to Article 5. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Commentary 4 to Article 5. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Commentary 7 to Article 5. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Commentary 12 to Article 5. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155. This paragraph contains a list, by no means exhaustive, of examples, each of which can be regarded, prima facie, as constituting a PE. As these examples are to be seen against the background of the general definition given in paragraph 1, it is assumed that the Contracting States interpret the terms listed, a "place of management," a "branch," an "office" etc in such a way that such places of business constitute a PE only if they meet the requirements of paragraph 1.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version, Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Article 4 and Commentary thereon. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Paragraph 5 of Article 5 and Commentary 31 to Article 5. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Paragraph 7 of Article 5 and Commentary 40-41 to Article 5. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.
OECD (2014). Model Tax Convention on Income and on Capital: Condensed Version 2014. Model Tax Convention on Income and on Capital: Condensed Version. Paragraph 6 to Article 5 and Commentary 36-39. doi:10.1787/mtc_cond-2014-en. ISBN 9789264211155.

oecd.org

"About Base Erosion and Profit Shifting (BEPS) - OECD". www.oecd.org. Retrieved 2016-03-15.
"Multilateral instrument for BEPS tax treaty measures: the Ad hoc Group - OECD". www.oecd.org. Retrieved 2016-03-15.
"Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7 - 2015 Final Report - en - OECD". www.oecd.org. Retrieved 2016-03-15.

sites.google.com

First tax treaty of 1899

un.org

"UN Model Tax Convention (2011)" (PDF).
See, e.g., 183 days in any 12-month period in the United Nations Model Tax Convention Article 5 paragraph 3(b).

ustreas.gov

See, e.g., the U.S./UK treaty Archived 2010-05-27 at the Wayback Machine Article 5, which is virtually identical to the OECD Model Article 5. The Nigeria/South Africa treaty Archived 2011-06-29 at the Wayback Machine Article 5, is nearly identical to the OECD Model Article 5, with the addition of a provision clarifying that a fixed place of business used as a sales outlet is a PE, notwithstanding exclusions elsewhere in the article.

web.archive.org

See, e.g., the U.S./UK treaty Archived 2010-05-27 at the Wayback Machine Article 5, which is virtually identical to the OECD Model Article 5. The Nigeria/South Africa treaty Archived 2011-06-29 at the Wayback Machine Article 5, is nearly identical to the OECD Model Article 5, with the addition of a provision clarifying that a fixed place of business used as a sales outlet is a PE, notwithstanding exclusions elsewhere in the article.