Dobry den,

surne potrebujem rozlusknut tento oriesok,je to bohuzial v anglictine. Zadanie je taketo:
Entity X is resident in country A and regarded as tax transparent under the latter's laws. Entity X is owned by individuals resident in country B which regards Entity X as a non-transparent company resident in country A.

Ignoring tax treaties and the existence of permanent establishments, will income which is received by Entity X be taxable in

(a) country A

(b) country B

(c) neither country A nor B

(d) both country A and B

a k tomu dalsia otvorena otazka :

How would your answer be, if it is assumed that there is an OECD-Model type of tax treaty concluded between country A and B and if the existence of permanent establishments is not denied?



prosim,cim skor
dakujem velmi pekne:)