Court rules commissionaire constitutes PE
April 11, 2011
Sophie Ashley - TPW
A Norwegian Court of Appeal ruled on March 2 that Dell AS, a Norwegian commissionaire company, constituted a sales agency permanent establishment (PE) in Norway because of its undisclosed Irish principal.
The Court ruled that 60% of the Norwegian source profits of the Irish company were taxable in Norway, in addition to the commission received by Dell AS.
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