Permanent Establishment for Investors in Private Equity Funds—A Legal Analysis in Light of the Changes to the OECD Model (2017)
The article analyzes whether the investment in a private equity fund may create a permanent establishment (PE) for foreign investors. The analysis is divided into two main parts, as the question of creating a PE for the foreign investors is considered with respect to both the main PE rule and the ag...
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| Format: | Article |
| Language: | English |
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Sciendo
2019-06-01
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| Series: | Nordic Tax Journal |
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| Online Access: | https://doi.org/10.1515/ntaxj-2019-0002 |