Several treaties with developing countries make an important exception to the permanent establishment principle in the context of fees for technical services. An example is found in the Gambian Treaty. Article 14 reads in part:

‘(1)Fees for technical services arising in one of the territories and paid to a resident of the other territory may be taxed in that other territory.

Need help? Get subscribed!

To subscribe to this content, simply call 0800 231 5199

We can create a package that’s catered to your individual needs.

Or book a demo to see this product in action.