Reinsurance PEs in LatAm Tax Treaties

On July 21, 1959, France and Germany signed a bilateral income tax treaty that bears a striking resemblance to modern-day tax treaties. Its original version had an Article 4th with provisions about business profits, Articles 7th, 9th, 10 and 15 with provisions about taxing rights on capital gains, dividends, interest and royalties, and even an Article 8th about permanent establishments (PEs)…

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