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The New Permanent Establishment
  • Language: en
  • Pages: 397

The New Permanent Establishment

  • Categories: Law
  • Type: Book
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  • Published: 2023-04-21
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  • Publisher: Leya

This work is the result of an extensive research into the permanent establishment concept, a concept that plays a vital role within the international taxation system through the fair allocation of taxing rights over cross-border business profits in the context of the tenuous balance between the residence and source principles, as a threshold for source taxation. Our research sought to explore and explain the evolution of this concept in the context of recent changes resulting from the joint work of the G20 and the OECD, namely under the aegis of the BEPS Project (Action 7), and later with the enactment of the Multilateral Instrument and the update to the OECD Model Convention. We also address the Portuguese permanent establishment concept and, finally, the future of the permanent establishment concept within the international taxation system.

He Looks So Fine: Part Two
  • Language: en
  • Pages: 533

He Looks So Fine: Part Two

  • Type: Book
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  • Published: 2024-09-19
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  • Publisher: Zelda French

"The first time Alberto watched a revenge flick, he was so mesmerised; he discovered something about himself: if the retaliation in the second half of the movie was satisfactory enough, there was no amount of abuse he couldn’t stomach in the first half. Catharsis, he found out it was called. Alberto was fond of that word. Catharsis." ♥ After spending the Christmas holidays together, Mathias and Alberto return to school disenchanted, and convinced of the other’s indifference. When they both find themselves in detention, they decide to skip school together, consequences be damned. But as they are inexorably pulled toward each other, their personal demons are working their hardest to keep...

The Atheneum
  • Language: en
  • Pages: 500

The Atheneum

  • Type: Book
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  • Published: 1826
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  • Publisher: Unknown

None

The Portfolio of Entertaining & Instructive Varieties in History, Literature, Fine Arts, Etc. ...
  • Language: en
  • Pages: 484
The Spirit of the English Magazines
  • Language: en
  • Pages: 456

The Spirit of the English Magazines

  • Type: Book
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  • Published: 1826
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  • Publisher: Unknown

None

The New-York Mirror, and Ladies' Literary Gazette
  • Language: en
  • Pages: 300

The New-York Mirror, and Ladies' Literary Gazette

  • Type: Book
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  • Published: 1824
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  • Publisher: Unknown

None

The Monthly Traveller, Or, Spirit of the Periodical Press
  • Language: en
  • Pages: 534

The Monthly Traveller, Or, Spirit of the Periodical Press

  • Type: Book
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  • Published: 1836
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  • Publisher: Unknown

None

All Our Wars
  • Language: en
  • Pages: 286

All Our Wars

For fans of Katie Gutierrez’s More Than You'll Ever Know and Netflix’s Narcos comes a high-stakes thriller about the daughter of a high-ranking Mexican cartel leader dragged back to the life she fought hard to escape. Twelve years have passed since Sofia De Luna’s mother was murdered. Sofia now leads a quiet life in Chicago, far from the cartel violence she was raised amidst. But when her narco father’s retirement catapults her to head of the family, that peaceful existence is upended. Unhappy with this changeover of power, Sofia’s brothers and cousins are wary of her desire to legitimize the family and her insistent questions about her mother’s mysterious death. Meanwhile, in Me...

The Literary Gazette
  • Language: en
  • Pages: 844

The Literary Gazette

  • Type: Book
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  • Published: 1826
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  • Publisher: Unknown

None

Individuals' Income Under Double Taxation Conventions
  • Language: en
  • Pages: 466

Individuals' Income Under Double Taxation Conventions

  • Categories: Law

This book analyses the treatment of income of individuals under Brazilian double taxation conventions. Each article of the Brazilian tax treaties is analysed in order to identify its characteristics, field of application, limits and criteria applied in the identification of taxpayers. The OECD Model Convention is also considered, since it is mirrored in Brazilian conventions. The analysis reveals the unconstitutional nature of Articles 17 and 19 of the Brazilian treaties as they contradict the constitutional principle of isonomy.