Reconstruction Concept of The Meaning of Permanent Establishment Physical Presence for Tax Purposes (2024)

Technological developments have fostered cross-border e-Commerce transactions. This study aims to reconstruct the concept of the meaning of physical presence in the criteria for identifying foreign individuals and foreign entities as permanent establishments. Reconstruction uses the terminology of physical presence, which is adjusted to the presence of a new post-pandemic order, namely maintaining distance in certain situations. The term maintaining distance is translated as the distance between foreign individuals, foreign entities, and service users. This study proposes a reconstruction of the concepts of physical presence, the subject of permanent establishments, and the objects of permanent establishments. The concept of Significant Economic Presence is relevant to the fulfilment of three criteria: revenue, digital, and user. The reconstruction of permanent establishments involves determining the digital and user aspects. Reconstruction of permanent establishments involves determining the digital aspect of income. This study proves the hypothesis that the addition of Significant Economic Presence criteria to the determination of permanent establishments in e-commerce transactions increases the fairness of taxation rights in the source country. Therefore, it is necessary to review the determination of permanent establishments, especially e-commerce transactions, which are not limited to a physical presence with a wider scope through revenue, digital, and user criteria. This study makes a theoretical contribution to the significance of economic presence by replacing the meaning of the physical presence of a permanent establishment. Thus, the potential for permanent establishment taxation is not limited to the potential value-added tax but can also be on the potential income tax.

Издание: JOURNAL OF TAX REFORM
Выпуск: Vol. 10, no. 1 (2024)
Автор(ы): Дармаяса Ньоман, Партика Дэва Мадэ
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Rhythms of Rhenium (2007)

On the basis of publications of recent years, the contemporary state of the world market for rhenium and the economics of production and trends of development of rhenium-containing products are reviewed.

Автор(ы): Наумов Аркадий Валерьевич
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REFLECTIONS ON THE CATEGORY COMPLEXITY AND THE THEORY OF COMPLEX SYSTEMS (2019)

The article presents a brief history of the formation of representations in the category of «complexity». Modern interpretations of the term in various Sciences are shown. The system approach to understanding complexity is most fully stated.

Издание: The complex systems
Выпуск: № 1 (6) (2019)
Автор(ы): Иванов Олег Петрович
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RELATIONSHIP BETWEEN EXTREME PRECIPITATIONS ON THE WESTERN COAST OF THE BLACK SEA AND MACROCIRCULATION PROCESSES (2020)

The paper discusses extreme precipitation recorded at 14 weather stations on the western coast of the Black Sea according to reanalysis data and at two weather stations according to observation data. Comparison of observation data with reanalysis data has been carried out. The relationship between extreme precipitation at each station and elementary circulation mechanisms (ECMs) has been analyzed according to typing by B.L. Dzerdzeevsky, V.M. Kurganskaya and Z.M. Vitvitskaya. The ECMs at which precipitation extremes were observed simultaneously at several stations were identified. It was determined at which ECMs on the western coast of the Black Sea extreme precipitation events occur most often and the multi-year changes in the duration of these ECMs were analysed.

Издание: The complex systems
Выпуск: № 4 (10) (2020)
Автор(ы): Кононова Нина Константиновна, Горбунова Татьяна Юрьевна, Велев Стефан Борисов
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RELATIONSHIP OF EXTREME PRECIPITATIONS ON THE EASTERN BLACK SEA COAST WITH MACROCIRCULATION PROCESSES (2020)

The paper discusses extreme precipitation recorded at 12 meteorological stations on the Eastern Coast of the Black Sea according to reanalysis data and at three stations according to their observations. Comparison of observational data with reanalysis data is carried out. The relationship between extreme precipitations at each station and elementary circulation mechanisms (ECMs) according to typification developed by B.L. Dzerdzeevsky, V.M. Kurganskaya, and Z.M. Vitvitskaya has been analysed. ECMs was revealed, at which precipitation extremes were noted simultaneously at several stations. It has been established at which ECMs on the Eastern coast of the Black Sea extreme precipitation most often occurs, and long-term changes in the duration of these ECMs are analysed.

Издание: The complex systems
Выпуск: № 3 (9) (2020)
Автор(ы): Кононова Нина Константиновна, Горбунова Татьяна Юрьевна
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RELATIONSHIP OF EXTREME PRECIPITATIONS IN THE CRIMEA WITH MACROCIRCULATION PROCESSES (2020)

The paper discusses extreme precipitation recorded at 23 weather stations in the Crimea. Reanalysis data were used. The relationship between precipitation at each station and elementary circulation mechanisms (ECMs) according to B.L. Dzerdzeevsky, V.M. Kurganskaya, and Z.M. Vitvitskaya has been analysed. The ECMs were revealed, at which precipitation extremes were noted simultaneously at several Crimean stations. It has been established at which ECMs in the Crimea, extreme precipitations most often occur and long-term changes in the duration of these ECMs were analysed.

Издание: The complex systems
Выпуск: № 3 (9) (2020)
Автор(ы): Кононова Нина Константиновна, Горбунова Татьяна Юрьевна
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