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The Regional Finance Office of Karlsruhe has issued a decree on whether the installation of an Internet server by a German resident entrepreneur in a foreign country creates a permanent establishment in that foreign country for German tax purposes. The decree states that the “Foreign Tax Relations” section of the federal state and the Lander have decided that, for the time being, the installation of an Internet server is to be treated as a preparatory act under Art. 5(4) of the OECD Model Convention and not as a permanent establishment.

A final decision will be made once the OECD has decided what is the correct treatment for Internet servers.


Article 5(4)(e) says “.. the term `permanent establishment` shall be deemed not to include: the maitenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character…”

At the date of writing the OECD have not yet decided on the correct treatment.


IFAs must not delay on stakeholder

Life offices are warning IFAs they risk missing the boat over stakeholder pension provision for corporate clients.The warning comes against the backdrop of a Government requirement for all firms to offer employees a stakeholder facility from April 2001.IFAs have been warned they face stiff competition from direct sales forces and sellers, such as Abbey Life […]

NatWest swipe at BoS

NatWest has hit out at the Bank of Scotland claiming it is avoiding key questions over the Edinburgh-based bank&#39s £22bn hostile takeover bid.The beleaguered bank also says BoS&#39s proposals do not stand up to examination and are characterised by rhetoric rather than detail.

First Quadrant acquires Prolific Objective Asset Management

Investment managers First Quadrant has acquired London-based Prolific Objective Asset Management.The deal will increase Quadrant&#39s £8.5bn in assets and overlays via the London office by about 10 per cent.POAM managing director Philip Ainsworth says: “The fit of our expertise and products with First Quadrant is excellent and offers genuine opportunities for us to build business […]

£12bn Annuities and Drawdown market for IFAs

Annuities and Drawdown are exciting and growing markets, worth £12bn to IFAs, according to The Income Drawdown Advisory Bureau director Robert Lymburn.In a speech to The Insurance Institute of London last week, he says it is a market which is becoming more specialised and dividing into three distinct segments.At the bottom of the market there […]


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