Subcontracting Services to a Company and a Permanent Establishment According to Article 5 Paragraph 3 Letter b) UN-Model-Convention - Intertax View Subcontracting Services to a Company and a Permanent Establishment According to Article 5 Paragraph 3 Letter b) UN-Model-Convention by - Intertax Subcontracting Services to a Company and a Permanent Establishment According to Article 5 Paragraph 3 Letter b) UN-Model-Convention 45 6/7

This articles examines the question whether subcontracting another company can amount to a Permanent Establishment (PE) according to Article 5 paragraph 3 letter b) UN-Model-Conventions. In doing this, it looks at alternative service-PE-clauses, decisions and regulations in other jurisdictions and the interrelationship with the PE-profit-allocation-clause and the non-discrimination-clause. It argues that a PE through subcontracting another company would lead to dissatisfactory results.

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