Double Taxation and Permanent Establishment (PE)

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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?

The activity carried out by the PE 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?

Construction PE 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?

Providing a credit to A Co Signup and view all the answers

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

Dividend taxation Signup and view all the answers

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

Common management Signup and view all the answers

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

Country where taxable Signup and view all the answers

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

Directors fees remuneration Signup and view all the answers

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

Mode of country where taxable 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?

Types of activities covered Signup and view all the answers

Which method is specifically used for eliminating Economic Double Taxation?

Foreign Permanent Establishment Exemption Signup and view all the answers

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

Taxable Income of a Tax Group Signup and view all the answers

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

Foreign Tax Credit Signup and view all the answers

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

Date of Formation and Cessation of a Tax Group Signup and view all the answers

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

Elimination of Economic Double Taxation Signup and view all the answers

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

Taxable Income of a Tax Group Signup and view all the answers

Double Taxation and Permanent Establishment (PE)

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