OrbitaxDanish Tax Authority Holds Multiple Projects At Same Property do Not Constitute PE Under Tax Treaty with Germany if Not Clearly Continuous
|Treaty Development|Denmark-Germany
The Danish tax authority (SKAT) has published a recent binding ruling concerning whether the time spent on two separate construction projects at the same property should be taken in aggregate for the determination of a permanent establishment (PE) under the Danish-German tax treaty. The binding ruling was sought by a German company that undertook construction projects in Denmark. The first pro…
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