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The Permanent Establishment Concept In International and Turkish Tax Law

Please find below the content of our publication called “The Permanent Establishment Concept In International and Turkish Tax Law”.
 
 
 
 
 
 
 
CONTENTS
 
INTRODUCTION
 
1. PART I: THE SCOPE OF THE STUDY
 
2. PART II: TREATY DEFINITIONS OF PERMANENT ESTABLISHMENT UNDER MODEL CONVENTIONS
 
  A. Physical Permanent Establishment
    i. The Place of Business
    ii. The Fixed Place and The Duration Test
    iii. The carrying on business whollypartly of the enterprise
    iv. Prima Facie Permanent Establishment
    v. Exceptions To Fixed Place Of Business: Preparatory and Auxiliary Activities
  B. Construction Permanent Establishment
  C. Agency Permanent Establishment
    i. General Rule
    ii. Exceptions to Agency Permanent Establishment
 
3. PART III: THE DEFINITION OF PERMANENT ESTABLISHMENT UNDER TURKISH TAX LAW
 
  A. General Information on Turkish Tax Regime
  B. Domestic Definition of Permanent Establishment under Turkish Tax Law (Tax Procedural Law, Income Tax Law and Corporate Tax Law)
    i. The Turkish Tax Procedure Law
    ii. The Turkish Income Tax Law
    iii. The Corporate Tax Law
  C. Treaty Position of Turkey under Tax Treaties
 
4. PART IV: ANALYSIS
 
5. CONCLUSION
 
BIBLIOGRAPHY
 

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