shopping_cart

Your shopping cart is empty

Business profits and permanent establishments paper

Member Price: $57.00
Non Member Price: $75.00

DisclaimerThis material is copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 18 Sep 08

This is an area where there is constant movement on multiple fronts all of which needs to be kept on the radar. This paper covers:

  • Australian developments
    • Tasman Group Services
    • recent private rulings on the existence of a permanent establishment
  • overseas developments
    • Knights of Columbus (Canada)
    • Morgan Stanley
    • DET Satellite
  • OECD developments
    • revised commentary to Article 7 of the OECD Model Treaty
    • revised commentary on profit attribution to permanent establishments.

Author profile

Andrew Mills CTA-Life
Photo of author, Andrew MILLS Andrew Mills, CTA-Life, is Chair of the Financial Reporting Council Australia, Acting Chair of the Board of Tax, Principal Fellow at Melbourne University Law School and a member of the ANU’s Tax and Transfer Policy Institute Advisory Board and the Executive Committee of IFA Australia Branch among other roles. Previously, Andrew was the Second Commissioner, Law Design & Practice, at the Australian Taxation Office from 2013–2019. Andrew has over 40 years’ experience in taxation, including periods in the ATO, commerce and the tax profession. Andrew was a Director (Partner) at Greenwoods & Freehills for more than 20 years and managing director of the firm from 2006 to 2011. Andrew was President of The Tax Institute in 2006–2007 and is a former Governor of the Taxation Research Foundation. Andrew holds qualifications in Business and Law and is a Chartered Taxation Adviser (Life), a Fellow of CPA Australia, a Graduate member of the Australian Institute of Company Directors and a Fellow of the Governance Institute of Australia. - Current at 06 January 2026
Click here to expand/collapse more articles by Andrew MILLS.

 

This was presented at International Tax Masterclass .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Foreign entities – Characterisation and treatment for Australian tax purposes

Author(s):  Alison RODI,  David WATKINS

Materials from this session:

Sharp edges in a modular world

Author(s):  Ian STANLEY

Materials from this session:

GST and the Internet: Don’t get caught in the web!

Author(s):  Stephen TOBIAS

Materials from this session:

Business profits and permanent establishments

Author(s):  Andrew MILLS

Materials from this session:

Further details about this event:

 

Copyright Statement