Permanent establishments - EY
Permanent establishments Recent trends and developments Page 2 Moderator Panel Tom Philibert Albena Todorova Catherine Mbogo Partner EY Senegal Partner EY Mozambique East Region Tax Leader EY Kenya Ide Louw Akinbiyi Abudu Director EY South Africa Partner EY Nigeria Panel Africa Tax Conference 2015 Page 3 Action 7 overview Revised Permanent establishment proposals Profit attribution Updates from across the African continent What should you do next? Africa Tax Conference 2015 Agenda Page 4 Action 7 overview Africa Tax Conference 2015 Page 5 Article 7 Profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a Permanent establishment situated therein.
Page 3 Action 7 overview Revised permanent establishment proposals Profit attribution Updates from across the African continent What should you do next? ...
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Income Tax Act 2007, Taxation (International and Other Provisions) Act, Attribution of Profits, ATTRIBUTION OF PROFITS TO PERMANENT ESTABLISHMENTS, Attribution, Permanent, Departmental interpretation and practice notes, LB&I International Practice Service Transaction Unit, Guidelines for requesting Mutual, Guidelines for requesting Mutual Agreement Procedure