Stoycho Dulevski
KEY ASPECTS ABOUT THE SUBSIDIARY
IN THE CONCEPT OF PERMANENT ESTABLISHMENT
Abstract:
The article deals with one of the cases when permanent establishment (PE) is not usually formed – the provision of Art. 5, para.7 of the Model Tax Convention on Income and Capital of Organisation for Economic Co-operation and Development (OECD). The main aim of the study is to outline its legal nature, focusing on the key points in it. Although it is not distinguished by particular challenges of theoretical and practical nature, there are certain aspects that need special attention, as they can be interpreted as an exception to what is written on it.
