In general, there is no difference to impose a income tax between industrial or commercial transactions and foreign investment funds transactions. But the latter has a tendency to do their business based on tax havens country or region. To solve this ...
In general, there is no difference to impose a income tax between industrial or commercial transactions and foreign investment funds transactions. But the latter has a tendency to do their business based on tax havens country or region. To solve this problem, it should be revise the dependant agents' regulations in corporation tax law and study the french cases. Also, the attribution method to permanent establishment is to be made in comparison with OECD or IFA guide lines.