Iran Tax Update
Analysis
On 12 August 2015, the Czech Senate approved the tax treaty signed earlier this year with Iran.
The main provisions are as follows:
Permanent establishment
The term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on.
The term "permanent establishment" likewise encompasses:
a building site or a construction, assembly or installation project or supervisory activities in connection therewith, but only where such site, project or activities continue for a period of more than twelve months;
the furnishing of services, including consultancy or managerial services, by an enterprise of a contracting state or through employees or other personnel engaged by the enterprise for this purpose, but only where activities of that nature continue in the territory of the other contracting state for a period or periods exceeding in the aggregate six months in any twelve month period.
Dividends