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CIHL4NGEO\FRYO EURO DOES IT AFFECT THE COLiCTRIES ASSOCMTED \\?TH THE EU? the slruatlons nhere rtslclenth and non-rcs~dents should be treatcd al~keOne nliqht lor example come to a different conclusion about the accounting requirements In Eutuua P a r t ~ c ~ p n t ~ o none looked at 11 s them purely from [he tau point of wen That is a modest proposal Further thought could also be glven to whether other d~recttax proT;lslons could be mclucied in the EC Treaty, almmg, as I suggested at the start, to assist harmon) rather than b a n g harlnonlzat~onmeasures I would put forward as a candidate for such treatment the whole of the taxatlon of permanent establ~shmentsI may be wrong but 1 think that most states dlscrlminate In some way agalnst permanent establishments compared with residents Some of these d~fferences may be necessary but I doubt lf they all are One could make the results more deflnlte than the Commentary to the OECD prompermanent establishment non-d~scr~minatlon slon mhlch 1s full of dlsputed interpretations and suggestions for settl~ngd~fferences In negotlatlons such as m connection with dlmdends received the applicatton of u~thholcllngidx LO d~xiclcnds tntcrest and ro>altles paid to
EC Tax Review – Kluwer Law International
Published: Jun 1, 1998
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