Domiciliul fiscal, sediul permanent ori locul conducerii efective a unei persoane juridice străine. Distincţii conceptuale şi semnificaţii juridice

Conf. univ. dr. Cristina ONEŢ

Universitatea "Lucian Blaga" din Sibiu

Facultatea de Drept

Keywords: competence of the tax authority, tax domicile, permanent establishment, place of effective management of a foreign legal entity, tax residence

The Tax Domicile, Permanent Establishment, and the Place of Effective Management of a Foreign Legal Entity. Conceptual Distinctions and Legal Implications

Abstract

The correct determination of the tax domicile, the permanent establishment, or the place of effective management of a foreign legal entity are aspects of particular importance in order to accurately establish which authority is competent to carry out certain procedures and, especially, which tax legislation is applicable to different categories of taxpayers in various situations or circumstances.

Thus, the present paper addresses in turn the concepts...