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Taxes

Force of attraction

One must understand the importance of a permanent establishment when it comes to taxation. This refers to the concept where a country taxes the income and property of a business located within its borders. However, it also extends to all income earned by the foreign head office from sources within the country and all property owned by the foreign head office situated in the country. Interestingly, the OECD model treaty does not allow the application of this concept.

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