Double Taxation and Permanent Establishment (PE)

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Questions and Answers

What is the main purpose of granting a credit by the Country of Residence to A Co?

  • To impose higher taxes on A Co
  • To encourage profit shifting
  • To reduce double taxation (correct)
  • To increase double taxation

Which of the following is NOT considered a type of Permanent Establishment according to Article 5 of the OECD MTC?

  • Fixed place PE
  • Import PE (correct)
  • Construction PE
  • Service PE

If an oil exploration machine is installed on an oil rig for exploring oil, what type of Permanent Establishment is it considered to be?

  • Construction PE
  • Equipment PE (correct)
  • Service PE
  • Fixed place PE

What determines the type of Permanent Establishment according to Article 5 of the OECD MTC?

<p>The activity carried out by the PE (B)</p> Signup and view all the answers

If a foreign enterprise is in the UAE for constructing a bridge or railway project, what type of Permanent Establishment does it constitute?

<p>Construction PE (C)</p> Signup and view all the answers

What action does the Country of Residence typically take to address potential double taxation issues related to the income of a Permanent Establishment?

<p>Providing a credit to A Co (B)</p> Signup and view all the answers

Which of the following is NOT considered a component of Permanent Establishment (PE)?

<p>Dividend taxation (C)</p> Signup and view all the answers

In the context of Associated Enterprises, what leads to the taxation of profits owing to a close connection?

<p>Common management (B)</p> Signup and view all the answers

Under the Capital Gains component, what aspect is covered in terms of taxation?

<p>Country where taxable (A)</p> Signup and view all the answers

Which type of services are covered under Dependent Personal Services in terms of taxation?

<p>Directors fees remuneration (B)</p> Signup and view all the answers

What does Remuneration for Directors Fees refer to in the context of taxation?

<p>Mode of country where taxable (C)</p> Signup and view all the answers

According to the information provided, what is a key feature of Income earned by entertainers in terms of its tax implications?

<p>Types of activities covered (B)</p> Signup and view all the answers

Which method is specifically used for eliminating Economic Double Taxation?

<p>Foreign Permanent Establishment Exemption (A)</p> Signup and view all the answers

What is the main focus of Group Taxation according to Article 40?

<p>Taxable Income of a Tax Group (D)</p> Signup and view all the answers

Under the Tax Treaties, which method provides relief from double taxation?

<p>Foreign Tax Credit (A)</p> Signup and view all the answers

What does Article 41 mainly regulate in terms of Tax Groups?

<p>Date of Formation and Cessation of a Tax Group (A)</p> Signup and view all the answers

In the context of double taxation, what does the Foreign Permanent Establishment (PE) Exemption address?

<p>Elimination of Economic Double Taxation (D)</p> Signup and view all the answers

Which aspect of taxation is covered in Article 42 concerning a Tax Group?

<p>Taxable Income of a Tax Group (D)</p> Signup and view all the answers

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