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TMI BlogFixed EstablishmentX X X X Extracts X X X X X X X X Extracts X X X X ..... and use services for its own needs; As per Education Guide Para no. 5.2.6, issued 20th Jun 2012 What is the meaning of a fixed establishment ? A fixed establishment is a place (other than the business establishment) which is characterized by a sufficient degree of permanence and suitable structure in terms of human and technical resources to provide the services that are to be supplied by it, or t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... usiness) but the actual rendering of the service is elsewhere (i.e. a fixed establishment)? Occasionally, a person may be the person liable to make payment for the service provided on his behalf to another person. For instance, the provision of a service may be negotiated at the headquarters of an entity by way of centralized sourcing of services whereas the actual provision is made at various loc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt (normally referred to as a recharge , reallocation , or a settlement ), these are generally made in accordance with corporate tax or other statutory requirements. These accounting arrangements also invariably aid the MLE's management in budgeting and financial performance measurement. Various accounting and business management systems are generally employed to manage, monitor and document t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g jurisdiction of service, which is provided under a 'global framework agreement' between two multinational companies with the business establishment located outside the taxable territory, but which is used or consumed by a fixed establishment located in the taxable territory, will be the taxable territory. - Manuals - Ready reckoner - Law and practice - Reference Guide - Quick Commentar ..... X X X X Extracts X X X X X X X X Extracts X X X X
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