Читать книгу International Taxation - Adnan Islam - Страница 44
Threshold of liability to foreign tax
ОглавлениеThe basis on which a foreign country taxes a branch of a U.S. company is generally a function of the level and quality of business activity carried out by that branch. In the case of most of the U.S. trading partners with which there are income tax treaties, the liability of the branch to local tax depends on whether the branch constitutes a permanent establishment within that country and whether the income in question derives from that permanent establishment.