18 Questions
What is the main purpose of granting a credit by the Country of Residence to A Co?
To reduce double taxation
Which of the following is NOT considered a type of Permanent Establishment according to Article 5 of the OECD MTC?
Import 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?
Equipment PE
What determines the type of Permanent Establishment according to Article 5 of the OECD MTC?
The activity carried out by the PE
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
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
Which of the following is NOT considered a component of Permanent Establishment (PE)?
Dividend taxation
In the context of Associated Enterprises, what leads to the taxation of profits owing to a close connection?
Common management
Under the Capital Gains component, what aspect is covered in terms of taxation?
Country where taxable
Which type of services are covered under Dependent Personal Services in terms of taxation?
Directors fees remuneration
What does Remuneration for Directors Fees refer to in the context of taxation?
Mode of country where taxable
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
Which method is specifically used for eliminating Economic Double Taxation?
Foreign Permanent Establishment Exemption
What is the main focus of Group Taxation according to Article 40?
Taxable Income of a Tax Group
Under the Tax Treaties, which method provides relief from double taxation?
Foreign Tax Credit
What does Article 41 mainly regulate in terms of Tax Groups?
Date of Formation and Cessation of a Tax Group
In the context of double taxation, what does the Foreign Permanent Establishment (PE) Exemption address?
Elimination of Economic Double Taxation
Which aspect of taxation is covered in Article 42 concerning a Tax Group?
Taxable Income of a Tax Group
Learn about how double taxation can occur for a company with business activities in two different countries, and how tax treaties aim to reduce this through credits. Explore the concept of Permanent Establishment (PE) as defined in Article 5 of the OECD Model Tax Convention.
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