الإخضاع الضريبي لأرباح المنشآت الدائمة وفقا لأحكام الاتفاقيات الجبائية بمنع الازدواج الضريبي

Abstract EN

The permanent establishment is one of the most important criteria adopted by tax treaties to avoid double taxation, in order to determine the right of the state to tax the taxpayer if all the necessary conditions are met in the establishment, which is generally a fixed place of business, or through the exercise of activities through a dependent agent, and in either case or another a contracting state may not tax the profits of another contracting state only if it carries on business through a permanent establishment in the other state confirmed by the article's text 07 of the Model Tax Convention of the OECD and the UNO, and even by the Algerian tax conventions.

Keywords: permanent establishment; double taxation