Permanent establishments and the mining industry - a roadmap to the taxation of resource-based activities under tax treaties

Catherine Brown

Research output: Contribution to journalArticleResearchpeer-review


The mining industry typically involves foreign expertise and personnel, and the taxation of the business profits generated is a heavily debated issue. Where there is a tax treaty in place, the right of the country to tax business profits sourced within its borders is further compounded by whether or not the foreign investor has a permanent establishment in that country. The permanent establishment concept is therefore central to the taxation rights of the country where the mining activity is being undertaken.
Original languageEnglish
Pages (from-to)4 - 12
Number of pages9
JournalAsia-Pacific Tax Bulletin
Issue number1
Publication statusPublished - 2012

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