Oliver R. Hoor
Abstract
The PE concept plays a prominent role in the tax treatment of cross-border business activities and is relevant to the application of domestic tax law and tax treaties. These two areas of law, however, do not use the same PE definition. This article analyses the PE definition under Luxembourg domestic tax law and for tax treaty purposes.
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The PE concept plays a prominent role in the tax treatment of cross-border business activities and is relevant to the application of domestic tax law and tax treaties. These two areas of law, however, do not use the same PE definition. This article analyses the PE definition under Luxembourg domestic tax law and for tax treaty purposes.
Key concepts: Tax treaty, Tax law, Law and economics, Business, Treaty, Double taxation, Economics, International economics