The permanent establishment (PE) is a legal form of cross-border direct investment whereby a business presence is maintained as an integral part of the foreign

This book provides an insight into business structuring and the related tax considerations. It covers all important aspects of fixed place of business and depen

This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and

Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduc

"Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regard