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permanent establishments (PEs).
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Permanent Establishment (PE) Art. 7(1) of the OECD and UN Model Conventions “The business
profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a
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Wrapped Around Your Finger (Black Lace) OECD/G20 Base Erosion and Profit Shifting Project . Additional Guidance on the
Attribution of Profits to Permanent Establishments, BEPS Action 7
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Alaska Permanent Fund is a constitutionally established
permanent fund managed by a state-owned corporation, the
Alaska Permanent Fund Corporation (APFC). It was established in Alaska in 1976 by Article 9, Section 15 of the Alaska State Constitution under Governor Jay Hammond.From February 1976 until April 1980, the Department of Revenue Treasury Division managed the state's
Permanent …
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Attribution of Profits to Permanent Establishments, which deals with work in relation to Action 7 of the BEPS Action Plan and the Revised Guidance on Profit Splits, which deals with work in relation to Actions 8-10 of the BEPS Action Plan.
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