Please find below the content of our publication called “The Permanent Establishment Concept In International and Turkish Tax Law”.

 

 

 

1. PART I: THE SCOPE OF THE STUDY

 

2. PART II: TREATY DEFINITIONS OF PERMANENT ESTABLISHMENT UNDER MODEL CONVENTIONS

 

  A. Physical Permanent Establishment

    i. The Place of Business

    ii. The Fixed Place and The Duration Test

    iii. The carrying on business whollypartly of the enterprise

    iv. Prima Facie Permanent Establishment

    v. Exceptions To Fixed Place Of Business: Preparatory and Auxiliary Activities

  B. Construction Permanent Establishment

  C. Agency Permanent Establishment

    i. General Rule

    ii. Exceptions to Agency Permanent Establishment

 

3. PART III: THE DEFINITION OF PERMANENT ESTABLISHMENT UNDER TURKISH TAX LAW

 

  A. General Information on Turkish Tax Regime

  B. Domestic Definition of Permanent Establishment under Turkish Tax Law (Tax Procedural Law, Income Tax Law and Corporate Tax Law)