Taxation of permanent establishment under Armenian law

Abstract

“When there is an income tax, the just man will pay more and the unjust less on the same amount of income” – Plato In the modern business environment, and apparently that of Plato’s time, organisations may wish to minimise their tax burden. In order to achieve the same, entities may operate on a global scale and endeavor to locate taxable profits in low tax jurisdictions. The operation of business on an international scale is not always tax driven. An international presence may be required due to the nature of business undertaken. The locating of business activities through different jurisdictions can result in different authorities claiming taxing rights. The vast international network of tax treaties endeavors to eliminate the potential to double taxation. The keystone to these treaties is the concept of permanent establishment.