2007EX282现代企业法租税法部分浅妻章如.PPTVIP

Key Issues relating to Permanent Establishment 9 October 2008 (15:30-17:00) ASATSUMA Akiyuki Rikkyo University (Tokyo) issues Why we need PE concept? PE FE (fixed establishment) Trigger of source tax Taxable income PE Attribution of profits to a PE PE electronic commerce Agent PE Profit sharing PE Why we need PE concept? (1) 2 kinds of tax jurisdiction on income Residence tax jurisdicion Source tax jurisdiction income flow Income earner ?----------- payer Residence country Source country Why we need PE concept? (2) Sometimes it is said that sour